Case 3:18-cv-01634-HZ Document 38 Filed 10/16/18 Page 1 of 40 Emily Teplin Fox, OSB No. 121720
[email protected] Marisa Samuelson, OSB No. 144234
[email protected] Beth Englander, OSB No. 980190
[email protected] Kelsey Heilman, OSB No.140348
[email protected] OREGON LAW CENTER 522 SW Fifth Ave, Suite 812 Portland, OR 97204 (503) 473-8325 Jonathan M. Dennis, OSB No. 146256
[email protected] OREGON LAW CENTER 35 SE Fifth Ave., Suite 1 Ontario, OR 97914 (541) 889-3296 Attorneys for Plaintiffs UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON PORTLAND DIVISION CINDY MENDOZA; GLORIA BERMUDEZ; Case No. 3:18-cv-01634-HZ JEREMY CHASE; CEKAIS TONI GANUELAS; REBECCA HEATH; and FIRST AMENDED CLASS ACTION KARL WADE ROBERTS, on behalf of ALLEGATION COMPLAINT themselves and all others similarly situated, Civil Rights Action (14th Amendment to Plaintiffs, U.S. Constitution (Due Process and Equal Protection) v. MATTHEW GARRETT, in his official capacity as Director of the Oregon Department DEMAND FOR JURY TRIAL of Transportation; TAMMY BANEY, in her official capacity as Chair of the Oregon Transportation Commission; SEAN Case 3:18-cv-01634-HZ Document 38 Filed 10/16/18 Page 2 of 40 O’HOLLAREN, in his official capacity as Member of the Oregon Transportation Commission; BOB VAN BROCKLIN, in his official capacity as Member of the Oregon Transportation Commission; MARTIN CALLERY, in his official capacity as Member of the Oregon Transportation Commission; and TOM MCCLELLAN, in his official capacity as Administrator of Driver and Motor Vehicles Division, Oregon Department of Transportation, Defendants.