IN THE CIRCUIT COURT OF THE STATE OF OREGON

FOR THE COUNTY OF MULTNOMAH

BRIAN EASON,

v.

ELMER'S RESTAURE3NTS, INC., an Oregon corporation,

ELMER'S FRANCHISE SYSTEMS, INC., an Oregon

corporation, KARSAN, INC., a Washington corporation,

and SANDRA LEWIS, an individual,

Defendants.

SUMMONS

To: Defendant Karsan, Inc., c/o LPSL Corporate Services, Inc.,

1420 Fifth Avenue, Suite 4200, Seattle WA 98101-2375.

You axe hereby required to appear and defend the complaint filed against you in

the above entitled action within thirty (30) days frorn the date of serv=ice of this

summons upon you, and in case of your failure to do so, for want thereof, plaintiffs)

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" y0U SIGNATURE OF ATTORNEY/AUTHO FOR. PLAINTIFF

must file with the court a 1ega1

paper called a "motion" or

"answer." The "motion" or "answer" Mark McDougal, OSB No. 890869

must be given to the court clerk or ATTORNEY'S/AUTHOR'S NAME and BA.R N0.

administrator within 30 days along Kafoury & McDougal

with the required filing fee. It 911 SW 2nd Ave, Ste 200

must be in proper form and have Portland OR 97204 (503) 224-2647

proof of service on the plaintiff's

attorney or, if the plaintiff does

not have an attorney, proof of

service upon the plaintiff. 7f you

have any questions, you should see

an attorney immediately. If you

need help in finding an attorney,

you may contact the Oregon State

Bar's Lawyer Referral Service

online at www.oregonstatebar.org or

by calling (503) 684-3763 in

Portland metropolitan area or toll

fxee elsewhere in Oregon at (800).

453-7636.

TO THE OFFICER OR OTHER PERSON SERVING THIS SUMMONS: Xou are hereby

directed to serve a true copy of this summons, together with a true

copy of the complaint mentioned therein, upon the individuals) or

other legal entity(ies) to whom ox which this summons is di.rectecl, and

to make your proof of service on the reverse hereof or upon a separate

similar document which you shall attach hereto.

Plaintiff, ) No. 15CV28990

~✓k~,,..,ha ~

ATTORNEY (S ) L'OR PLAT N I FF (S )

EX~~9~IT~

Case 3:15-cv-02335-SI Document 2-1 Filed 12/15/15 Page 1 of 15
~s;~, ,~`LNOV 13 2015

~~ftRE 3 - o~ ATTY cam.

-,~,,,a,~ ~,-,b,~.

~, :.-~ ~

Case 3:15-cv-02335-SI Document 2-1 Filed 12/15/15 Page 2 of 15
10/27/2015 9:54:11 AM

15CV289S0

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IN THE CIRCUIT COURT OF THE STATE OF OREGGN

FOR THE COUNTY OF MULTNOMAH

BRIAN EASON,

~ Case No.:

Plaintiff, )

COMPLAINT FOR DISCRIMINATION

v. ) (42 U.S.C. ~ 1981, 42 U.S.C. ~ 2000a,

and RCWA 49.60.030)

ELMER'S RESTAURANTS, INC., an )

Oregon corporation, ELMER'S ) NOT SUBJECT TO 1'vIANDATORY

FRANCHISE SYSTEMS, INC., an ) ARBITRATION

Oregon corporation, KARSAN, INC., a ~ p~YER: X100,000 'Washington corporation, and SANDRA ORS 21.150(1)(c) LEWIS, an individual, ~

JURY TRIAL DEMANDED Defendants. ~

Plaintiff demands a juzy trial and alleges:

1.

Defendants Elmer's Restaurants, Inc., and. Elmer's Franchise Systems,

Inc., (hereinafter, "Elmer's Restaurants") are and at all times mentioned herein

have been Oregon corporations engaged in the restaurant business, including

four restaurants located in Multnomah County, Oregon and a restaurant

located at 7105 NE 40th St., Vancouver, VVA near Andresen Road (hereinafter

"the Andresen Elmer's"). Elxner's Restaurants canducts regular, sustained

business activity in Multnomah County and is headquartered in Multnomah

County.

2.

Defendant Karsax~., Inc. (hereinafter, "Kansan") is and at all times

mentioned herein has been a Washington corporation engaged in the

PAGE 1 - COMPLAINT FOR DISCRIMINATION xnFovxY e. ~~novaxi,

411 SW' 2^d Ave., Suite 200

Portland, OR 97204

Fax:503-224-2673

Phone:503-224-2647

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restaurant business. Kansan owns and aperates the Andresen Elmer's, which

is an Elmer's Restaurants franchise. At all times mentioned herein, the agents

and employees of Kansan, including but not limited to Lewis and Hope

mentioned in paragraphs 3 and 4 below, were actual or apparent agents of

Elmer's Restaurants.

3.

r Defendant Sandra Lewis (hereinafter, "Lewis") is and at all times

mentioned herein has been co-owner, president, chairman, and director of

Kansan.

4.

On or about December 16, 2014, plaintiff was a customer at the

Andresen Elxner's. He had chosen this restaurant because it was not far from

his realty office, and he wanted a quiet place to enjoy breakfast while writing

out Christmas cards for his client list. He was seated at a table and prepaxed

to order his meal. The waitress, a woman named Hope, took his order, but

demanded that he prepay for his meal. The plaintiff asked why, anal the

waitress explained that she was acting on instructions from the owner, a

woman. later identified as Lewis.. The waitress apologized, acknowledging that

the policy was racist but continuing to demand prepayment. The plaintiff

prepaid as was demanded of him.

Other customers present in the restaurant that morning, who were

Caucasian, were not required to prepay for their meals.

~~

~~

~~

PAGE 2 - COMPLAINT FOR DISCRIMINATION ~g~URY & McDOUGAI.

411 SW 2^d Ave., Suite 200

Portland, OR 97204

Fax:503-224-2673

Phone:503-224-2647

Case 3:15-cv-02335-SI Document 2-1 Filed 12/15/15 Page 4 of 15
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FOR A FIRST CLAIM FOR RELIEF FOR DISCRIMINATION, plaintiff

~ alleges:

6.

Plaintiff realleges and incorporates by reference paragraphs 1 through 5,

(above.

7.

Plaintiff is African-American. At alI times mentioned herein, plaintiff was

well and appropriately dressed. Plaintiff is employed as a :sheriff's deputy in

Multnomah County, and as a realtor.

$.

The Andresen Elmer's is and at all times mentioned herein has been a

place of public accommodation within the meaning of RCWA 49.60.030. At

least part of the motivation for the above-described conduct by defendant

Elm.er's Restaurants' employees and agents was the plaintiff s race.

9.

The above-described conduct violates ROTA 49.60.030, which prohibits

discrimination in places of public accommodation on account of race.

10.

As a result of the above-described discrimination, plaintiff suffered loss

of sleep and feelings of racial stigmatisation, and. continues to suffer, and will

in the future suffer from feelings of racial stigmatization, all to his noneconomic

damages in the amount of $100,000.

11.

Plaintiff is entitled to costs anal reasonable attorney fees pursuant to

RCWA 49.60.30.

PAGE 3 - COMPLAINT FOR DISCRIMINATION KAFOURY h M¢DOUGAL

411 SW 2^d Ave., Suite 200

Portland, OR 97204

Fax:503-224-2673

Phone:503-224-2647

Case 3:15-cv-02335-SI Document 2-1 Filed 12/15/15 Page 5 of 15
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FOR A SECOND CLAIM FOR RELIEF FOR DISCRIMINATION, plaintiff

alleges:

12.

Plaintiff realleges and incorporates by reference paragraphs 1 through 7,

above.

' 13.

The Andresen Elmer s is and at all times mentioned herein has been a

place of public accommodation within the meaning of 42 U.S.C. § 2000a. At

least part of the motivation for the above-described conduct by defendant

Elmer's Restaurants' employees and agents was the plaintiff's race.

14.

The above-described conduct violates 42 U.S.C. ~ 2000a, which prohibits

discrimination in places of public accommodation on account of race.

15.

Plaintiff is entitled to injunctive relief, along with costs and reasonable

attorney fees pursuant to 42 U.S.C. ~ 2000a.

FOR A THIRD CLAIM FOR RELIEF FOR DISCRIMINATION, plaintiff

alleges:

16.

Plaintiff realleges and incorporates by reference paragraphs 1 through 7,

above.

17.

The above-described conduct violates 42 U.S.C. ~ 1981, which prohibits

interference with the right to make and enforce contracts on account of race.

~~

~~

PAGE 4 - COMPLAINT FOR DISCRIMINATION KAFOIIRY & McDOUGAL

411 SW 2~d Ave., Suite 200

Portland, OR 97204

Fa~c: 503-224-2673

Phone;503-224-2647

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As a result of the above-described discrimination, plaintiff suffered

loss of sleep and feelings of racial stigmatization, and continues to suffer, and

will in the future suffer from feelings of racial stigmatization, all to his

noneconomic damages in the amount of $100,000.

19.

Plaintiff is entitled to costs and reasonable attorney fees pursuant to 42

U.S.C. ~ 1988.

i►~~l

Plaintiff is entitled to punitive damages.

WHEREFORE, plaintiff prays for judgment against defendants in the

amount of $1Q0,000 in noneconomic damages, for punitive damages, for

reasonable attorney fees pursuant to 42 U. S. C. ~ 1981 and RCWA 49.60.030,

for injunctive relief and reasonable attorney fees pursuant to 42 U.S.C. ~

2000a, and for costs and disbursements necessarily incurred herein.

Dated: October 26, 2015.

/ s/ Mark McDougal

Gregory Kafoury, OSB #741663

kafoury~a~kafourymcdougal. com

Mark McDougal, OSB # 890869

mcdougal@kafourymcdougal. com

Jason Kafouxy, OSB #091200

j kafoury@kafourymcdougal. com

Attorneys for Plaintiff

PAGE 5 - COMPLAINT FOR DISCRIMINATION KAFOURY 6 McDOUGAL

411 SW 2^a Ave., Suite 200

Portland, OR 97204

Fa~c: 503-224-2673

Phone:503-224-2647

Case 3:15-cv-02335-SI Document 2-1 Filed 12/15/15 Page 7 of 15
~, NOV 13 2015

~'`~ ~.~dlVl~ i~~~~~.L ~'C ~~~9E—~ ATfY

,~ ~ '~ r ~° `a .

Case 3:15-cv-02335-SI Document 2-1 Filed 12/15/15 Page 8 of 15
IN 'SHE CIRCLI~T COURT OF TAE STATE QF OREC:p~

FOR THE COiJI~'TY OF 11~U~.T1ITO~H

BRIAN EATON,

Plai~ti.~f',

v,

ELMER'S ~ESTAURA.,NTS, INC., an Oregon cor~oratipr~,

~LMER'S FRAIVCH~S~ SYSTEM, TNC., azz Oregon

corporation, KARSAN, TNC., a Washington corporation,

and SANDRA L~WIS, an individual,

De~'endants.

To: De~exzdant Sandia Lewis,

705 NE 4Q~ Street, V'ancouvex WA 9$661.

No. 15CV28990

You are hexeby z-~quired to appear a~ad defend the complaint ~1,ed against you inn the above entitled action withiz~ thirty (3Q) daye from the date of servxc~ of this

summons upon you, and ~iz~ case of your failure to do so, for waxzt thereof, pi~intiff(s)

w~i11 apply to the court fox the relief denaaaded in tb,c complaint.

N47'ICE TO DBFEND~I,IVT: READ THESL

PAPERS C~It~B'tTl,LY

You must "appear" in this casE

or the other side will win

automatically, To "appear" you

must file with khs court a legal

paper ca1].ed a "motion" or

^answer-" The "moti0ri" or "answer"

must be given 'to the couz'~ clerk or

administzator within 30 dais alon,q

wa,til the required filing fee. Tt

must be i~, pxpp~r fazv~ end have

proof of sexvice on the plaintiff's

attgrney ar, if the plaintiff does

not have an attprrzex, proof p£

sarv~ee upon the plaintiff. If you

.have .aa}~..questic~raT_~,ou sllpul~d see

an atCorney immedi'ate~,y. If 'you

need help in fir~d,~.ng an attorney,

you, may contact the Oregon Stste

bar's t~awyez Referxal Service

online at www.oregonstatebsr.org or

by calling X503) 689-.3763 in

Portland metxopolftan area or ~0 1

free elsewhere in pxegon at (800)

4537636.

TO THE OFFICER OR pTEiER PERSO S

directed to serve a txue co~~+ of

copy o~ the complaint mention d

otkzer legal entit~(i~s) to wh ~n

~v make your proof of service on

similar document which you sh 11

~''~

SIGNATURE OF ATTORNEY/7►vTAO A PLA.YNTZFR

Mark McDougal, OSB No. 890869

A,TTO1tNEY'S/AUTHOR'S NAME and HAR N0.

Kafoury & N~cAougal

411 5LP ,Z'd F1P4~ StB 200

Port~,and 0R 9729 (503) 229-26Q7

• .. 

.. 

.. ,.ti,r~ • r . ~.

ERVING THIS SCJM[~20NS: You are herby

this summons, togetb~r with a true

thexeXn, upon the i,ndividual(s) or

oz which this atiurimons is directed, ar~d

th~~zeverse hereof Qz~ upon a separate

attach hereto.

~ ~'l

ATTORNEX (S ) FOR PLAIN F~' (5}

EYe~~i~9T. ~ —~

Case 3:15-cv-02335-SI Document 2-1 Filed 12/15/15 Page 9 of 15
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1pd27/20156:54:11 AM

h5CV28990 ~ tI ~" 1

~ i~ ~(~ ~~ 1: ~I~a ~ D i

r__...~

~ DEC 11 2015

~.H~~~ ~°~u~l~~~, PC

IN THE CIRCUIT COURT OF THE STATE OF OREGON

FOR THE CO~CJNTY OF MULTNOMA~I

s~arr E~.soN,

~laiintiff,

v.

ELMER'S RESTAUktt,A,.N'TS, INC., an

Oregon corpor~,tipn, ELMER'S

FRANCHISE SYSTEMS, INC., ala. ~ Oregon corporation, SAN, INC., a

Washington corporation, and SANDRA ;

LEWIS, an indiaidual,

Defendaxa,ts.

Case No.:

COMPLAINT FaR DISCRIMYNATION

(42 U.S.C. ~ 19$X, 42 CJ.S.C. ~ 2000a,

and RCWA 49.60.030)

NOT SUBJEC'x"Y'O MANDATORY

ARBITRATYON

PRA,I'~R: $100, 000

ORS 21.160(1)(c~

JURY TRIAL DEN~ANbED

Plainta:ff demands a jury' trial grad alleges:

1.

~Defendar~ts E1~ner's ~,2estaurants, Xnc., and Elmer's Franchise Syste~ocas,

Ync., (herein,a~`ter, "Elmer's Restaurax~.ts") are and at a~~ times mentioned herein

have been Oregon corporations engaged in the restaurant business, including

four restaizrants~ located zn-~~Vlultnozx~ah County, Oregon az~,d a restaurant =~

located at 7105 N'~ 40~► St., Vancouver, WA near Andresen Road (Yaereinafter

"the Andresen Elmer's"). Elmer's Restaurants conducts regulaar, sustained

business activity in, Multnomah County axed is headquartered in Multnomah

County.

Defendant Karsan, Ync. (herein,aftier, "Karsax~") is and at all times

mentioned herein has been a Washington corporation engaged in the

PAGrE 1 - COMPLAINT FOR DISC~TMINATION snaooaY e~ scanov~.

411 SAD' 2+~ AVG., 9uiu 2O0

portlarul, OR 97204

.. Bax:503-224-2673

Phone: 503-22a-2647

Case 3:15-cv-02335-SI Document 2-1 Filed 12/15/15 Page 10 of 15
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restaurant business, Kaxsan owns and operates tie Andresen E~rn.er's, w~~ch

is an Elmer's Res~aurax~,ts ~r~chise. A.t all times zza.entioned h,exein, the sgex~ts

and employees o~ Karsan, ~ncludix~g buff not ~ixnited 'to Leovis and Tope

m~.ntipx~ed in paragraphs 3 az~d 4 below, were acfual or apparent agents of

El.zxa,er's Restaurants.

Aefendasxt Sandra Lewis (hereinafter, ~~.ewis") is axxd at all times

m~ex~tioned herein has b~;en co-owner, president, chairman, and director of

Karsat~.

4.

On or about December 16, 2014, plair~t~~£ was a customer at ttxe

Andre~ex~ Elmer's, He had chosen tk~i.s restau~azit because it was riot far from

his realty office, and he wa,r~ted a quzet place to enjoy brea~East while w,~itin~

out Christxrxas cards for his clzent list, H~ was seated a~ a table and prepared

to order his xz~eal. The waitress, a womax~ xzamed I~ope, took his oxder, bit

demaxided that he prepay for his meal. The p~aixitiff asked why, and the

waitress explained that she was acting o~. instructioxas from the Qwxier, a•

~wom~an later identified. as J.ewis. '~"he waitress apologized, acknowledging that

the-policy w,a,s racist -but continu~n~g to demand, pre~ay~nent. ~The~ p~aantiff - ~~

prepaid as ~r~s dezxxanded of kxim.

5.

Other cu.stom~;rs present in th.e restaurant that morning, who vaere

Caucasian, were x~ot required to prepay for their meaXs.

~~

//

~~

PAGE 2 - COMP~,AINT FOR TaISCRIIVMIaVATION 1fAFOV1tY~MeDOUC}AL

al i 9W 2~d Ave., 3~ito 200

Portland, OR X7204

Fau:503-2?R-2673

Phnrk. 503-2242647

Case 3:15-cv-02335-SI Document 2-1 Filed 12/15/15 Page 11 of 15
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FORA FIRST CLAIM FOR RELIEF FpR DISCRIMINA,TZ()N, plaintiff

~1leges:

6.

Plaintiff xealleges atxd incorporates by referera,ce paragraphs ~ through 5,

above.

7.

Plaintiff is African-Ax~n,ex~ican. A.t all times mentioned herein, plaintiff was

v~ell and appro~rXately dressed. Plaintiff ~s ex~ployed as a sY~ex~ff's deputy iz~

Multr,o~uah County, axxd as a realtor.

S.

The ,Ax~.dresen Elrr~ex's is and at all times mentioned herein has been a

p~ac~ of public accommodation within the meaning of ~~WA 49.60.030. At

feast dart of the motivation for the $bove-described conduct by defendaxit

~lzner's Restaurants,' employees and agents ~xras the plaintiff's race.

9.

'~~.e above-described conduct violates RCWA 49.60.030, which prohibits

discriminataoz~ in places o~ public accoxamodation ors account of racy.

]. Q.

- ~ As a resukt ~f~~he above=d~scrabed discriminatio~a,; piain~~iff ~suff~:red loss

of sleep az~d feelings o~ xaeial s~i.gmatiization, and continues to suffer, azid will

in. the future suffer ~'xom feelings of racial sti.gr~atazation, all to his noneconomic

daxaages in the arr~ount of X104,000.

11.

Plaintiff is ex~ta~t~ed to costs axed re~asonabl~ attvz~xey fees pUrsua~t to

RCWA 49.60.030.

PAGE 3 - COMPLAINT FOR DZSCRIMTN'ATIO~v KAp'OOSY & D1cDOIIGAL

4J.1 SW 2~ Ave., Suite 20p

Yortl~md, OR 97204

1 :v~ 503-224-2673

Phone:503=224-2647

Case 3:15-cv-02335-SI Document 2-1 Filed 12/15/15 Page 12 of 15
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FOR A S~COIVD CLAIM FOR RELIEF FOR D~SCRIMINATYON, plaintiff

alleges:

Z2.

F'~aintiff reallegea and incorporates by ~e~ez~ence paragraplxs 1 through 7,

above.

13.

~k~c Andresem Elmer's is axad at all times rmentioned herein ktas been a

place of pUb~ic aGcommodatiozi, vv~ithin the meaziing n~' 42 U.S.C. E 200Qa. At

Least part of th.e motivatiari ~'or the above-described conduct by defendazat

Elmez~'s Restaurants' emplopee9 and agents was the plaintiff's cace.

. 14.

The above-described conduct violates 42 U.S.C. ~ 2000a, w,k~ach prohibits

disczaamination in places of public accommodation vn account of race.

15.

Plaintiff ~s ~z~titlEd to itijuzactive relief, a~oz~g with costs and reasonable

attorney fees pursuazxt to ~2 U.S.C. ~ 2000a.

FOR A THIRD CL,AxM FOR RELIEF FOR DISCRIIV~T1vATION, plaintiff

alleges:

T,~'laintiff, reallege~ azxd incarpor~,t~s by reference paragraphs .1~tkirough 7,

above.

17.

Tha above-described conduct rrialatcs 42 U.S.C. § 1981, which prohSlaxts

zntez~£erence with the xigkat to make and en~'oz~ce contracts on account of r~.ce.

~~

~~

PAGE 4 — CO,MPL,A.INT FOR DISC~INATION R* a ~~~~

411 3W 2~+A,ve., Suite 200

Ppr4Aad, OR 97x04

Fax: 503-224.673

Phm~c: 503-224644

Case 3:15-cv-02335-SI Document 2-1 Filed 12/15/15 Page 13 of 15
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,A,s a result of the above-described discriznimatiion, plaintiff suffered

Goss of sleep and ~eeai~gs of racial atig~n.atization, and continues to suffer, and

will in the future s~x~ffez~ from feelings of raraat stigrna~zatian, all to his

nonecox~ozaxc damages in the azx~,ount of $100,000_

1~.

Plaintiff ~s entitled tv costs aiad reasonable attorney fees pursuant to 42

U.S.C. ~ 19$S.

zo.

P~aix~,tiif is entitled to puxutive damages.

WHEREFORE, plaintiff prays for judgment against defe.~dants in the

arx~.ouz~t Qf $100,000 ice, xzoneconomic daxx~ages, for punitive damages, ~'vz~

reasonable attvrrxey fees ~rur~uaxAt to 42 U.S.C. g ~98X and RCWA 49.60.030,

four i,z~junctive relief azxd reasonable attorney fees pursuant to 4~ U.S.C. ~

2000a, and for costs a~zd disbursements necessarily incurred herein,

Dated: October 26, 20J.5.

/s/ Mark McDougal

Gregory Kafoury, osB ~~41663

kafoury[akafQurym~cdougal.com

.._... ....,__.. ... __._.._._ _., _....., _._... ..... .Mark M~Do~~a1~, ~B. #..89~86~ .; .._ __--.~...._......

cncdaugalQkafourymcdouga~.com

Jason Kafoury, OSH #09200

j kafoury~kafouzyzzxcdougai. com

Attorneys fox Plaintiff

PAGE S - COMPL,A~NT FOR DISCRIMINATION a~►rovaY w escnovicei,

411 9W 2~ Ave., Suite 200

Yvrtload, OR 97204

le~C 503•~74.Z673

Phoac, 503.29A-2647

Case 3:15-cv-02335-SI Document 2-1 Filed 12/15/15 Page 14 of 15
CERTIFICATE OF SERVICE

I hereby certify that on December 14, 2015, I caused to he served a copy of the foregoing

DErENDA.NTS KARSAN, INC. ANL~ SANDRA LEWIS'S NOTICE OF REMOVAL on the

following persons) in the manner indicated below at the following address(~s):

Gregory Kafoury, Esc.

Marlc Gillis McDougal, Esq.

mcdougal cr kafourymcdougal. com

Jason Llewellyn Kafoury, Esq.

Kafoury &McDougal

411 SW Second Avenue, Suite 200

Portland, OR 97204-3408

Elizabeth E. Lampson, Esq.

elampson@d~visrothwell. corn

Davis Rothwell Earle & Xochihua P,C.

111 Southwest Fifth Avenue, Suite 2700

Portland, Oregon 97205-3650

p by CM/ECF

CJ1 by Electronic Mail

[] by Facsimile Transmission

Q by First Class 1Vlail

p by I~aa~d Delivery

[] by Overnight Delivery

PAGE 4 - DEFEND~INTS KARSAI~i, INC. AND SANDRA LEWIS'S NOTII":E OF

REMOVAL

LANE POWELL ec

601 SW SECOND AVENUE, SUITE ?.100

707613.0002/6509440.1 PORTLAND, OREGON 97204-3 1 5 8

503.7782100 FAX: 503.778.2?.00

Case 3:15-cv-02335-SI Document 2-1 Filed 12/15/15 Page 15 of 15