Case 6:21-cv-01709-MK Document 1 Filed 11/27/21 Page 1 of 39

Meredith Holley (she/her), OSB No. 125647

Meredith@ErisResolution.com
Law Office of Meredith Holley
207 E 5th Avenue, Suite 254
Eugene, OR 97401
Phone: (458) 221-2671
Fax: (833) 352-3615
Attorney for Plaintiff

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF OREGON
EUGENE DIVISION

Case No. 6:21-cv-1709

AMANDA MCINTYRE,
Plaintiff, COMPLAINT
(Sexual Harassment, Gender
vs. Discrimination, Dissemination of
Intimate Images, Impersonation,
CITY OF SPRINGFIELD – SPRINGFIELD Violation of Right to Intimate
POLICE DEPARTMENT, an Oregon Association, Violation of Right to
municipal agency; ROBERT WEAVER, in Free Speech)
his individual capacity; THOMAS RAPPE,
in his individual capacity; RICHARD
LEWIS, in his individual capacity;
Demand for Jury Trial
SPRINGFIELD POLICE ASSOCIATION, an
Oregon mutual benefit labor
organization; and PATRICIA PERLOW, in
her individual capacity,
Defendants.

INTRODUCTION
1.

Before 1910, male law enforcement officials completely excluded women from

working as law enforcement officers in the United States. In 2019, male law

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enforcement continued to exclude women from careers in law enforcement so

severely that nationally, on average, only 12.5% of full-time law enforcement
officers were female. One historical justification for excluding women from law
enforcement roles is the argument that with a woman present, men are not able to
sexually control themselves. The argument that women are responsible, but men
are not responsible, for sexual contact is also a historical justification for rape and
other violence against women.
2.
In 2019, male law enforcement officers at Defendant City of Springfield –
Springfield Police Department (Defendant SPD) excluded women from careers in
law enforcement at a higher rate than the national average. At that time, only 7%

of Defendant SPD’s officers were women.

3.
In 2020, Defendant SPD hired Plaintiff Amanda McIntyre, assigning her to train
in a group of all-male instructors, trainees, and supervisors. Defendant SPD’s
officers and administration treated Ms. McIntyre differently, telling her she
needed to be quieter than men, but also that she needed to prove herself by
“getting in a bigger fight” than her male colleagues. When Ms. McIntyre’s male
superior officers engaged in sexual conduct with her, Defendant SPD fired Ms.

McIntyre, but did not even discipline the men.

4.
The individual defendants and Defendant Springfield Police Association worked
together to protect favored male officers, such as Defendant Robert Weaver, from
discipline. They worked together to prevent Ms. McIntyre from any career in law
enforcement by placing her on the Lane County District Attorney’s Office Brady

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List because of statements they allege she made regarding private, off-duty sexual
conduct of male officers at Defendant SPD.

JURISDICTION AND VENUE

5.
This matter arises under federal law, 42 U.S.C. § 1983 and 42 U.S.C. 2000e.
Supplemental jurisdiction over related state law claims is proper under 28 U.S.C.
§ 1367.
6.
The events underlying Plaintiff’s claims took place in Lane County, Oregon,
making venue proper in the District of Oregon, Eugene Division.

PARTIES
7.
Plaintiff Amanda McIntyre is a resident of Lane County, Oregon. She is a woman.
On August 31, 2020, she became the only female recruit in her training class with
the Springfield Police Department.
8.

Defendant City of Springfield – Springfield Police Department (hereinafter

Defendant SPD) is a municipal government entity in Lane County, Oregon.
Defendant SPD employed Plaintiff from August 31, 2020, to December 2, 2020.
Upon information and belief, at all times relevant to this complaint all of
Defendant SPD’s leadership was male.

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9.
Defendant Springfield Police Association (hereinafter Defendant Police Union) is
an Oregon mutual benefit labor organization with its principal place of organizing
in Lane County, Oregon. Defendant Police Union is in the business of union
representation of Defendant SPD’s police officers. At all times relevant to this
complaint, Defendant Police Union represented Defendant Robert Weaver. Upon
information and belief, at all times relevant to this complaint, all of Defendant
Police Union’s leadership was male.
10.
Defendant Richard Lewis is a resident of Lane County, Oregon. Defendant Lewis
was the Chief of Springfield Police Department at all times relevant to this

complaint until his employment ended on or about June 1, 2021. At all times
relevant to this complaint, Defendant Lewis had authority over Defendant SPD to
set policies, customs, and/or practices. At all times during Plaintiff’s employment
with Defendant SPD, Defendant Lewis had supervisory authority over Plaintiff.
11.
Defendant Thomas Rappe is a resident of Linn County, Oregon. Defendant Rappe
is a lieutenant at Defendant SPD. At all times relevant to this complaint,
Defendant Rappe had authority over Defendant SPD to set policies, customs,

and/or practices. At all times during Plaintiff’s employment with Defendant SPD,
Defendant Rappe had supervisory authority over Plaintiff.
12.
Defendant Robert Weaver is a resident of Lane County, Oregon. Defendant
Weaver is a detective at Defendant SPD. Defendant Weaver’s primary duties as a
detective are related to computer searches and technology. Specifically, Detective

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Weaver handles child pornography collection and review in cases alleging

possession of illegal and abusive pornography. Detective Weaver is a firearms
instructor with Defendant SPD and instructed Plaintiff on firearms use during her
employment with Defendant SPD.
13.
Defendant Patricia Perlow is a resident of Lane County, Oregon. Defendant
Perlow is the Lane County District Attorney. Defendant Perlow has ultimate
decision-making authority over the Lane County District Attorney’s Office Brady
List. Defendant Perlow is sued in her individual capacity.

FACTUAL ALLEGATIONS
14.
Around April 2020, Plaintiff Amanda McIntyre applied to become a police officer

with Defendant SPD. She was 25 years old at the time. Ms. McIntyre was inspired
to become a police officer from listening to a popular podcast, hosted by officers
from Defendant SPD. She was very excited and star-struck when she learned that
one of the hosts of the podcast was conducting her background check.

15.
On August 26, 2020, Defendant SPD recruited Plaintiff Amanda McIntyre to
become a police officer. She was the only woman in her training class and was 26
years old at the time.
16.
As soon as Ms. McIntyre began working, officers told her, “You have to fit the
mold of a Springfield Police Officer and if you don’t, you won’t make it.” Soon,
she learned Defendant SPD has a reputation for excessive force and fighting.

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Officers told her, “Everyone needs to prove they can fight, and women have to get
in a bigger fight than men to prove they can be trusted as backup.” Ms. McIntyre
occasionally saw one other female officer on a shift, but otherwise all of the
officers Defendant SPD assigned to work with her were men.
17.
On September 20, 2020, Defendant Weaver invited Ms. McIntyre to his home for
special firearms training. After the training, Defendant Weaver initiated sex with
Ms. McIntyre. That night, Defendant Weaver texted Ms. McIntyre, “I’m not your
superior! I’m just a coworker.”
18.
On September 24, 2020, Ms. McIntyre told Defendant Weaver that she did not

want to have sex with him again.

19.
In October 2020, Wendy Polen, the assistant to the Chief of Police, told Ms.
McIntyre, “You’re too flirtatious. You should tone it down. Don’t talk to people
unless they talk to you first.” Ms. McIntyre did not hear Ms. Polen say this or
anything like this to her male colleagues.
20.
Also in October 2020, Sgt. Grice told Ms. McIntyre, “Fighting is a big deal, and

women have to get in a bigger fight than men to prove to their fellow officers they
can be trusted when it comes to having backup.”
21.
On October 10, 2020, Ms. McIntyre was injured at work. Ms. McIntyre’s male
supervisor, Officer Bronson Durrant, took her to the emergency room. Officer
Durrant has a reputation for violence, including violence against women. Officer

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Durrant was very volatile during Ms. McIntyre’s training, often yelling at her and
demeaning her differently than her male counterparts. At the emergency room,
Officer Durrant refused to leave the triage room while the nurse asked Ms.
McIntyre personal medical questions. Ms. McIntyre asked if she needed to answer
medical questions in front of Officer Durrant, and he refused to leave.
22.
On November 6, 2020, Ms. McIntyre’s training group had Emergency Vehicle
Operations Course Training. At lunch, one of the older male training officers
turned his chair so that it was specifically facing away from Ms. McIntyre and
ignored her throughout the lunch, though he responded to all of the men at the
lunch. Later that day, another officer told Ms. McIntyre that the older training

officer was “known for being a misogynistic jerk.”

23.
On November 14, 2020, another officer told Ms. McIntyre that Defendant Weaver
was bragging that he had sex with her. Ms. McIntyre felt humiliated and was
worried about her reputation in the department.
24.
On November 18, 2020, Ms. McIntyre’s supervising watch commander, Sgt.
Kirkpatrick, accused Ms. McIntyre of “lack of force” in an altercation. He

threatened her position, so she reached out to Sgt. Grice to ask his advice. Sgt.
Grice intervened and said Ms. McIntyre had done everything she should do based
on her training and experience.
25.
Later, on November 18, 2020, Lieutenant George Crolly called Ms. McIntyre and
told her that he believed she was in a “toxic learning environment,” and that she

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would be placed with a female training officer for the rest of her training. It
seemed like Lt. Crolly was saying that Ms. McIntyre was being targeted as the
only female recruit and that Sgt. Kirkpatrick was trying to enforce the rule that
because she was a woman Ms. McIntyre needed to prove herself by getting into a
serious fight.
26.
On November 20 and 23, 2020, Ms. McIntyre had sex with Sgt. Grice. Sgt. Grice
told Ms. McIntyre that they were not in a relationship and that he did not want to
be in a relationship. He texted, “I just need to know that it never gets out. Ever.
I’m worried I just threw my credibility, career and ethics out the window.”
27.

Defendant SPD defines, “Workplace Romance” as follows:

A relationship that occurs between two members of an

organization where sexual attraction is present, affection is
communicated, and both members recognize the relationship to be
something more than just professional and platonic.
Defendant’s policy regarding Workplace Romance requires the supervising
employee to report the “workplace romance.” Defendant SPD has not provided
Plaintiff any policy that addresses sexual contact that does not result in a
“relationship” that is “more than just professional and platonic.”

28.
Upon information and belief, neither Defendant Weaver nor Sgt. Grice reported
their sexual contact with Ms. McIntyre.
29.
In the early morning of November 24, 2020, suspecting that Ms. McIntyre was
with Sgt. Grice, a male officer, while on duty, abandoned his post and drove to

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Sgt. Grice’s home, which is far from any cross streets and at the end of a dead-end
private neighborhood road. That officer drove to the end of the dead-end street
and saw Ms. McIntyre’s car. That officer called Sgt. Kirkpatrick, Ms. McIntyre’s
supervising sergeant, and told Sgt. Kirkpatrick he had left his post, driven to Sgt.
Grice’s house, and seen Ms. McIntyre’s car there. Sgt. Kirkpatrick then also
deviated from his assigned post and drove to Sgt. Grice’s house to look at Ms.
McIntyre’s car. Upon information and belief, neither officer has been disciplined
for leaving their posts to surveil off-duty officers.
30.
On November 25, 2020, Defendant Tom Rappe confronted Ms. McIntyre, saying
she was “under investigation” for having an “inappropriate relationship” with Sgt.

Grice. Ms. McIntyre truthfully told him “I do not have a relationship with Sgt.
Grice.” Defendant SPD has not provided any policy definition of “inappropriate
relationship.”
31.
On November 26, 2020, Ms. McIntyre asked her training supervisor whether there
was any policy that would prohibit officers from having sexual contact. Ms.
McIntyre explained that she and Sgt. Grice had slept together. The training
supervisor said she did not see any reason the contact would be an issue because

Sgt. Grice was not Ms. McIntyre’s direct supervisor.

32.
On November 27, 2020, Defendant Rappe and two other men, Lt. Crolly, Sgt.
Grice’s best friend, and Officer Robert Conrad, the President of Defendant Police
Union, questioned Ms. McIntyre. Ms. McIntyre did not have union protection at
the time, but Union President Conrad did represent Defendant Weaver as a union

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member. Upon information and belief, all three men had seen nude photos of Ms.
McIntyre at the time of this investigation interview, either through Defendant
Weaver disseminating photos of Ms. McIntyre or through seizing and searching
Sgt. Grice’s phone.
33.
The three men closed Ms. McIntyre into a room and began interrogating her about
her private, off-duty sexual conduct. Defendant Rappe asked Ms. McIntyre for
personal details about sexual interactions with Sgt. Grice. He accused Ms.
McIntyre of being sexually “aggressive.”
34.
Defendant SPD’s policy regarding truthfulness, General Order 26.1.1 XII(10),

makes it clear that supervisors for Defendant SPD are not entitled to private
information about officers’ off-duty conduct, defining “Truthfulness” as follows:

Truthfulness: Members shall truthfully answer all questions from

persons of higher rank which are specifically directed and
narrowly related to the scope of employment and operations of the
Department.

Nevertheless, on November 27, 2020, Defendant Rappe accused Ms. McIntyre of

untruthfulness because she did not agree that she was in an “inappropriate

relationship” with Sgt. Grice.

35.
Defendant Rappe gave Ms. McIntyre a “Memorandum,” dated November 27,
2020, saying “This memorandum is to advise you that you are the subject of an
investigation for an allegation of misconduct pertaining to a relationship with a
male supervisor.” The memorandum identified Defendant Rappe as the Acting

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Chief of Defendant SPD. He suspended Ms. McIntyre from duty as of November

30, 2020.
36.
At no point on November 27, 2020, or at any other time, did any representative of
Defendant SPD notify Ms. McIntyre of any rule, policy, or other regulation that
prohibited the sexual contact between her and Sgt. Grice.
37.
On December 2, 2020, Defendant Lewis told Ms. McIntyre that she was fired for
saying, “I do not have a relationship with Sgt. Dave Grice.” Lt. Crolly, Sgt.
Grice’s best friend, escorted Ms. McIntyre off the premises.
38.

On the night of December 2, 2020, Ms. McIntyre spoke with Sgt. Grice, and he
described how the department handled the investigation with him, which was very
different from how the department handled it with her. For example, Sgt. Grice
said the lieutenants had immediately taken his phone and reviewed their private
text messages and photos. They never asked him whether he was in a
“relationship” with Ms. McIntyre.
39.
On December 7, 2020, Defendant Lewis issued a notice of separation about Ms.

McIntyre’s employment to the Oregon Department of Public Safety Standards and

Training as follows:
a. Defendant Lewis answered “No,” to the question, “Was the separation
the result of (even in part) an active or pending investigation being
conducted by your agency or another public agency into allegations of
misconduct involving the separated individual?”

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b. Defendant Lewis stated as the reason for Ms. McIntyre’s separation,

“McIntyre failed to candidly answer a superior officer’s question
regarding non-work related activity.”
40.
After Ms. McIntyre’s termination, another officer told Ms. McIntyre that other
officers at Defendant SPD refer to Ms. McIntyre as the “bicycle recruit,” which
he says is a sexually derogatory statement that officers could “take a ride” on her.
He has also said to her that male police officers are allowed to be sexually active,
but female officers have to be “pure.”
41.
In early January, 2021, another officer told Ms. McIntyre that a detective with

Defendant SPD had created a card he was passing around the precinct showing
Sgt. Grice and Defendant Weaver as “Eskimo brothers,” a term referring to two
men who had sex with the same woman. This was humiliating and degrading to
Ms. McIntyre.
42.
Also in early January 2021, another officer told Ms. McIntyre that Defendant
Weaver had shown sexually explicit photos of her to officers and staff within the
department, specifically to Lt. Crolly and Officer Conrad, who had been present

in the November 27, 2020 investigation interview. Defendant Weaver did this
after Ms. McIntyre said she would not have sex with him anymore.
43.
On January 22, 2021, Ms. McIntyre provided valid Tort Claims Notice to
Defendant SPD under ORS 30.275.

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44.
On February 18, 2021, another officer told Ms. McIntyre that Defendant Weaver
had created a fake phone account, represented himself as Ms. McIntyre, and
texted another officer a nude photo of Ms. McIntyre’s torso.
45.
Defendant SPD has represented that Defendant Weaver admitted to showing Ms.
McIntyre’s nude photos to other officers and impersonating her on a fake phone
account. Upon information and belief, Defendant SPD has not disciplined
Defendant Weaver or prosecuted him criminally.
46.
Upon information and belief, Defendant Police Union, including its President,

Officer Conrad, have interfered with attempts to discipline Defendant Weaver for
the actions alleged in this complaint and that has contributed to the lack of
discipline against Defendant Weaver.
47.
Upon information and belief, Sgt. Grice has not been disciplined for any conduct
related to Ms. McIntyre.
48.
In early 2021, Defendant SPD hired an attorney to conduct an investigation into

conduct alleged in this complaint. Upon information and belief Defendant SPD
held out that investigator as independent, although the investigator was not
licensed under ORS 703.405.
49.
On February 23, 2021, Amanda McIntyre filed a complaint with the Oregon
Bureau of Labor and Industries and Federal Equal Opportunity Commission.

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50.
On June 21, 2021, Ms. McIntyre learned that Defendant Lewis recommended to
Defendant Perlow that Ms. McIntyre be added to the Lane County District
Attorney’s Office Brady List, and that Defendant Perlow added Ms. McIntyre to
Brady List. This means that Defendant Lewis and Defendant Perlow have
classified Ms. McIntyre within law enforcement as not qualified to testify in a
trial. Neither Defendant Lewis nor Defendant Perlow notified Ms. McIntyre of
this action or gave her any chance to formally respond to or refute this allegation.
The action of Brady listing Ms. McIntyre prevents her from being hired as a law
enforcement officer in the future.
51.

On September 9, 2021, the Oregon Bureau of Labor and Industries issued Plaintiff
a 90-day right to sue letter.

52.
Defendants’ actions and inactions have caused Plaintiff harms in an amount to be
determined by a jury at trial, including therapy expenses, wage loss, severe
emotional distress including humiliation, pain, sleeplessness, degradation, suicidal
thinking, and other emotional traumas. Ms. McIntyre loved training as a police

officer and dreams of going into law enforcement again, but knows that she likely
will not be able to do, especially if she continues to be Brady listed. Ms. McIntyre
has even feared for her life, knowing that if she is in danger and needs police
assistance, she may not be able to call Defendant SPD to respond. Compensation
for Ms. McIntyre’s harms should be determined by a jury at trial.

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FIRST CLAIM FOR RELIEF – TITLE VII, 42 U.S.C. § 2000E,

HOSTILE WORK ENVIRONMENT SEXUAL HARASSMENT
(AGAINST DEFENDANT SPD)
53.
Plaintiff repeats and realleges paragraphs 1-52 as though fully set forth.
54.
Defendant violated Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e,
et seq., by subjecting Plaintiff to unwanted, offensive verbal or physical conduct,
based on her sex, such as the following:
(a) Discriminatory comments saying that “women need to get into a bigger
fight than men,” that Plaintiff should only speak when spoken to, that
women need to be sexually pure while men can have sex, accusing
Plaintiff of lacking enough force based on the stereotype that women are
weaker than men, and ignoring Plaintiff because she is a woman;
(b) Sexually derogatory statements regarding Plaintiff including that she was

a “bicycle recruit” officers can ride, calling men who had sex with
Plaintiff “Eskimo brothers,” and accusing Plaintiff of being sexually
“aggressive”;
(c) Creating a Christmas card that was sexually derogatory to Plaintiff;

(d) Creating a fake phone account, impersonating Plaintiff and disseminating

at least one image of her;
(e) Disclosing and/or seizing and viewing one or more photos of Plaintiff,
which identified Plaintiff and in which Plaintiff’s intimate body parts were
visible;
(f) Accusing Plaintiff of having an “inappropriate relationship” with Sgt.
Grice without defining what that meant or any concerns implicating the
workplace;
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(g) Closing Plaintiff in a room with three older, male superior officers and
asking her about her sexual conduct;
(h) Investigating Plaintiff’s private, off-duty sexual conduct because she is a
woman;
(i) Accusing Plaintiff of misconduct in order to cover up sexual conduct of
superior male officers;
(j) Misrepresenting the nature of Plaintiff’s termination on legal forms;
and/or
(k) Asking Defendant Perlow to Brady list Plaintiff for allegations based on
private, off-duty conduct.
The conduct was severe or pervasive enough to alter the conditions of Plaintiff’s

employment and create a work environment that a reasonable person in Plaintiff’s

circumstances would consider to be abusive or hostile enough to alter the
conditions of Plaintiff’s employment. Plaintiff perceived the environment to be
abusive or hostile. Defendant and/or members of Defendant’s management knew
or should have known of the harassment and failed to take immediate, appropriate
remedial action reasonably calculated to end the harassment as described above,
instead engaging in the conduct and/or trying to cover it up. This culminated in
Defendant SPD disciplining Plaintiff for “lack of force,” and terminating Plaintiff.

55.
Defendant’s actions and inactions have caused Plaintiff harms in an amount to be
determined by a jury at trial, including therapy expenses, wage loss, severe
emotional distress including humiliation, pain, sleeplessness, degradation, suicidal
thinking, and other emotional traumas. Ms. McIntyre loved training as a police
officer and dreams of going into law enforcement again, but knows that she likely

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will not be able to do so if she continues to be Brady listed. Ms. McIntyre has
even feared for her life, knowing that if she is in danger and needs police
assistance, she may not be able to call Defendant SPD to respond. Compensation
for Ms. McIntyre’s harms should be determined by a jury at trial.
56.
Plaintiff is entitled to reasonable attorney fees and costs under 42 U.S.C. § 2000e-
5.

SECOND CLAIM FOR RELIEF – ORS 659A.030

HOSTILE WORK ENVIRONMENT SEXUAL HARASSMENT
(AGAINST DEFENDANT SPD)
57.
Plaintiff repeats and realleges paragraphs 1-56 as though fully set forth.
58.
Defendant SPD violated ORS 659A.030 by subjecting Plaintiff to unwanted,

offensive verbal or physical conduct, based on her sex, such as the following:
(a) Discriminatory comments saying that “women need to get into a bigger
fight than men,” that Plaintiff should only speak when spoken to, that
women need to be sexually pure while men can have sex, accusing

Plaintiff of lacking enough force based on the stereotype that women are
weaker than men, and ignoring Plaintiff because she is a woman;
(b) Sexually derogatory statements regarding Plaintiff including that she is a
“bicycle recruit” officers can ride, calling men who had sex with Plaintiff
“Eskimo brothers,” and accusing Plaintiff of being sexually “aggressive”;
(c) Creating a Christmas card that was sexually derogatory to Plaintiff;
(d) Creating a fake phone account, impersonating Plaintiff and disseminating
at least one image of her;
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(e) Disclosing and/or seizing and viewing one or more photos of Plaintiff,
which identified Plaintiff and in which her intimate body parts were
visible;
(f) Accusing Plaintiff of having an “inappropriate relationship” with Sgt.
Grice without defining what that meant or any concerns implicating the
workplace;
(g) Closing Plaintiff in a room with three older, male superior officers and
asking her about her sexual conduct;
(h) Investigating Plaintiff’s private, off-duty sexual conduct because she is a
woman;
(i) Accusing Plaintiff of misconduct in order to cover up sexual conduct of

superior male officers;

(j) Misrepresenting the nature of Plaintiff’s termination on legal forms;
and/or
(k) Asking Defendant Perlow to Brady list Plaintiff for allegations based on
private, off-duty conduct.
The conduct was severe or pervasive enough to alter the conditions of Plaintiff’s
employment and create a work environment that a reasonable person in Plaintiff’s
circumstances would consider to be abusive or hostile enough to alter the

conditions of Plaintiff’s employment. Plaintiff perceived the environment to be

abusive or hostile. Defendant and/or members of Defendant’s management knew
or should have known of the harassment and failed to take immediate, appropriate
remedial action reasonably calculated to end the harassment as described above,
instead engaging in the conduct and/or trying to cover it up. This culminated in
Defendant SPD disciplining Plaintiff for “lack of force,” and terminating Plaintiff.

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59.
Defendant’s actions and inactions have caused Plaintiff harms in an amount to be
determined by a jury at trial, including therapy expenses, wage loss, severe
emotional distress including humiliation, pain, sleeplessness, degradation, suicidal
thinking, and other emotional traumas. Ms. McIntyre loved training as a police
officer and dreams of going into law enforcement again, but knows that she likely
will not be able to do so if she continues to be Brady listed. Ms. McIntyre has
even feared for her life, knowing that if she is in danger and needs police
assistance, she may not be able to call Defendant SPD to respond. Compensation
for Ms. McIntyre’s harms should be determined by a jury at trial.
60.

In the actions and inactions described above and incorporated herein, Defendant
SPD acted with malice and/or has shown a reckless and outrageous indifference to
a highly unreasonable risk of harm and a conscious indifference to the health,
safety, and welfare of others. Plaintiff is entitled to have a jury determine punitive
damages under ORS 659A.885 in an amount sufficient to deter similar conduct in
the future.
61.
Plaintiff is entitled to reasonable attorney fees and costs under ORS 659A.885.

THIRD CLAIM FOR RELIEF – 42 U.S.C. § 1983

FOURTEENTH AMENDMENT EQUAL PROTECTION VIOLATION - MONELL
(AGAINST DEFENDANT SPD)
62.
Plaintiff repeats and realleges paragraphs 1-61 as though fully set forth.

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63.
At all times relevant to this complaint, Defendants Weaver, Rappe, and Lewis,
and other decisionmakers for Defendant SPD were acting individually and jointly
under color of state law and within the scope of their employment with Defendant
SPD.
64.
Defendant SPD violated Plaintiff’s right to equal protection under the Fourteenth
Amendment of the United States Constitution in one or more of the following:
(a) Creating, interpreting, and/or implementing policies, customs, or practices
that create discrimination against women as described above, and/or cover
up the sexual harassment, discrimination, or sexual misconduct of men;

and/or
(b) In that Defendant SPD’s employees who dictate final policy, custom or
practice, Defendants Lewis and Rappe took actions that discriminate
against women, including Plaintiff, as described above and in the cases
Umenhofer v. Grimaldi et al., U.S. District Court of Oregon Case No.
6:14-cv-01575-TC, and Nichol v. Springfield et al., U.S. District Court of
Oregon Case No. 6:14-cv-01983-AA, resulting in policy, custom, or
practice at Defendant SPD of discrimination against women.

65.
Defendant’s actions and inactions have caused Plaintiff harms in an amount to be
determined by a jury at trial, including therapy expenses, wage loss, severe
emotional distress including humiliation, pain, sleeplessness, degradation, suicidal
thinking, and other emotional traumas. Ms. McIntyre loved training as a police
officer and dreams of going into law enforcement again, but knows that she likely

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will not be able to do so if she continues to be Brady listed. Ms. McIntyre has
even feared for her life, knowing that if she is in danger and needs police
assistance, she may not be able to call Defendant SPD to respond. Compensation
for Ms. McIntyre’s harms should be determined by a jury at trial.
66.
Plaintiff is entitled to reasonable attorney fees and costs under 42 U.S.C. § 1988.

FOURTH CLAIM FOR RELIEF – ORS 659A.403

DISCRIMINATION IN PUBLIC ACCOMMODATION
(AGAINST DEFENDANT SPD)
67.
Plaintiff repeats and realleges paragraphs 1-66 as though fully set forth.
68.
Defendant SPD is a place of public accommodation in that it is owned or
maintained by a public body, is open to the public, and/or offers services to the

public by a public body.

69.
Defendant SPD violated ORS 659A.403 by failing to offer full advantages,
accommodations, facilities, and privileges to women who are private citizens,
including Plaintiff, that it offers to men, in one or more of the following:

(a) In creating and maintaining a culture of harassment against women

including derogatory comments, like the comment that Plaintiff was a
“bicycle recruit” on whom male officers could take a ride;
(b) In creating and disseminating a Christmas card characterizing men who
had sex with Plaintiff as “Eskimo brothers”;
(c) In disclosing, viewing, seizing, or failing to discipline male officers who
disclosed, viewed, or seized, nude images of Plaintiff;

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(d) In failing to discipline a male officer who used technology to harass,

intimidate, and humiliate women, including Plaintiff; and/or
(e) In failing or refusing to investigate potential crimes against women
including but not limited to those alleged above.
70.
Defendant’s actions and inactions have caused Plaintiff harms in an amount to be
determined by a jury at trial, including therapy expenses, wage loss, severe
emotional distress including humiliation, pain, sleeplessness, degradation, suicidal
thinking, and other emotional traumas. Ms. McIntyre loved training as a police
officer and dreams of going into law enforcement again, but knows that she likely
will not be able to do so if she continues to be Brady listed. Ms. McIntyre has

even feared for her life, knowing that if she is in danger and needs police
assistance, she may not be able to call Defendant SPD to respond. Compensation
for Ms. McIntyre’s harms should be determined by a jury at trial.
71.
In the actions and inactions described above and incorporated herein, Defendant
SPD acted with malice and/or has shown a reckless and outrageous indifference to
a highly unreasonable risk of harm and a conscious indifference to the health,
safety, and welfare of others. Plaintiff is entitled to have a jury determine punitive

damages under ORS 659A.885 in an amount sufficient to deter similar conduct in

the future.
72.
Plaintiff is entitled to reasonable attorney fees and costs under ORS 659A.885.

COMPLAINT – Page 22
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FIFTH CLAIM FOR RELIEF – ORS 659A.030

AIDER AND ABETTOR
(AGAINST DEFENDANT WEAVER)
73.
Plaintiff repeats and realleges paragraphs 1-72 as though fully set forth.
74.
At all times relevant to this complaint Defendant Weaver was acting in the scope
of his employment with Defendant SPD.
75.
Defendant Weaver violated ORS 659A.030 by aiding, abetting, inciting,
compelling, or coercing Defendant SPD into its discrimination against Plaintiff in
one or more of the following:
(a) In disclosing one or more photos of Plaintiff, which identified Plaintiff and
in which intimate body parts were visible; and/or
(b) In creating a fake phone account and impersonating Plaintiff in order to

distribute at least one photo, identifying her, to another officer;

Defendant Weaver took these actions in order to retaliate against Plaintiff for
refusing to continue to have sex with him or in order to harass, degrade,
embarrass, or humiliate her as a woman.

76.
Defendant’s actions and inactions have caused Plaintiff harms in an amount to be
determined by a jury at trial, including therapy expenses, wage loss, severe
emotional distress including humiliation, pain, sleeplessness, degradation, suicidal
thinking, and other emotional traumas. Ms. McIntyre loved training as a police
officer and dreams of going into law enforcement again, but knows that she likely
will not be able to do so if she continues to be Brady listed. Ms. McIntyre has
even feared for her life, knowing that if she is in danger and needs police
COMPLAINT – Page 23
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assistance, she may not be able to call Defendant SPD to respond. Compensation
for Ms. McIntyre’s harms should be determined by a jury at trial.
77.
In the actions and inactions described above and incorporated herein, Defendant
SPD acted with malice and/or has shown a reckless and outrageous indifference to
a highly unreasonable risk of harm and a conscious indifference to the health,
safety, and welfare of others. Plaintiff is entitled to have a jury determine punitive
damages under ORS 659A.885 in an amount sufficient to deter similar conduct in
the future.
78.
Plaintiff is entitled to reasonable attorney fees and costs under ORS 659A.885.

SIXTH CLAIM FOR RELIEF – ORS 30.833

DISSEMINATION OF INTIMATE IMAGE
(AGAINST DEFENDANT WEAVER)
79.
Plaintiff repeats and realleges paragraphs 1-78 as though fully set forth.
80.
At all times relevant to this complaint Defendant Weaver was acting in the scope
of his employment with Defendant SPD.

81.
Defendant Weaver violated ORS 30.833 by knowingly disclosing one or more
photos of Plaintiff, which identified Plaintiff and in which intimate body parts
were visible. Defendant Weaver had intent to harass, humiliate or injure Plaintiff.
Defendant knew or reasonably should have known that Plaintiff did not consent to
the disclosure. Plaintiff was harassed, humiliated or injured by the disclosure. A

COMPLAINT – Page 24
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reasonable person would be harassed, humiliated or injured by the disclosure.

There was no lawful purpose or public interest in the disclosure.
82.
Defendant’s actions and inactions have caused Plaintiff harms in an amount to be
determined by a jury at trial, including therapy expenses, wage loss, severe
emotional distress including humiliation, pain, sleeplessness, degradation, suicidal
thinking, and other emotional traumas. Ms. McIntyre loved training as a police
officer and dreams of going into law enforcement again, but knows that she likely
will not be able to do so if she continues to be Brady listed. Ms. McIntyre has
even feared for her life, knowing that if she is in danger and needs police
assistance, she may not be able to call Defendant SPD to respond. Compensation

for Ms. McIntyre’s harms should be determined by a jury at trial.

83.
Plaintiff is entitled to punitive damages and reasonable attorney fees and costs
under ORS 30.833.

SEVENTH CLAIM FOR RELIEF – ORS 30.863

IMPERSONATION
(AGAINST DEFENDANT WEAVER)
84.

Plaintiff repeats and realleges paragraphs 1-83 as though fully set forth.
85.
At all times relevant to this complaint Defendant Weaver was acting in the scope
of his employment with Defendant SPD.

COMPLAINT – Page 25
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86.
Defendant Weaver violated ORS 30.863 by intentionally impersonating Plaintiff
in a communication to another officer with the intent to injure Plaintiff. Defendant
Weaver intended the other officer to believe he was Plaintiff in his
communication. A reasonable person in the circumstances of the other officer
would have believed Defendant Weaver was Plaintiff. Defendant Weaver injured
Plaintiff’s in her reputation, privacy, and personal safety within her community.
87.
Defendant’s actions and inactions have caused Plaintiff harms in an amount to be
determined by a jury at trial, including therapy expenses, wage loss, severe
emotional distress including humiliation, pain, sleeplessness, degradation, suicidal

thinking, and other emotional traumas. Ms. McIntyre loved training as a police
officer and dreams of going into law enforcement again, but knows that she likely
will not be able to do so if she continues to be Brady listed. Ms. McIntyre has
even feared for her life, knowing that if she is in danger and needs police
assistance, she may not be able to call Defendant SPD to respond. Compensation
for Ms. McIntyre’s harms should be determined by a jury at trial.

88.

Plaintiff is entitled to reasonable attorney fees and costs under ORS 30.863.

EIGHTH CLAIM FOR RELIEF – ORS 659A.030

AIDER AND ABETTOR
(AGAINST DEFENDANT RAPPE)

89.
Plaintiff repeats and realleges paragraphs 1-88 as though fully set forth.

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90.
At all times relevant to this complaint Defendant Rappe was acting in the scope of
his employment with Defendant SPD.
91.
Upon information and belief, Defendant Rappe has a history of sexual misconduct
and has covered up sexual misconduct of other male officers in the past, at least
some of which conduct was documented in a notebook retained by the City of
Springfield. Defendant Rappe’s history of sexual misconduct, covering up for
other male officers, and discrimination against women has resulted in an unsafe
environment for women, including Plaintiff, at Defendant SPD.
92.

Defendant Rappe continued his pattern of discrimination against women in

violation of ORS 659A.030 by aiding, abetting, inciting, compelling, or coercing
Defendant SPD into its discrimination against Plaintiff in one or more of the
following:
(a) Seizing and viewing one or more photos of Plaintiff, which identified
Plaintiff and in which Plaintiff’s intimate body parts were visible;
(b) Accusing Plaintiff of having an “inappropriate relationship” with Sgt.
Grice without defining what that meant or any concerns implicating the

workplace, but using different language with Sgt. Grice;

(c) Closing Plaintiff in a room with three older, male superior officers and
asking her about her sexual conduct;
(d) Accusing Plaintiff of being sexually “aggressive” because she expressed
desire for sex while off-duty;

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(e) Investigating Plaintiff’s private, off-duty sexual conduct because she is a

woman; and/or
(f) Accusing Plaintiff of misconduct in order to cover up sexual conduct of
superior male officers.
93.
Defendant’s actions and inactions have caused Plaintiff harms in an amount to be
determined by a jury at trial, including therapy expenses, wage loss, severe
emotional distress including humiliation, pain, sleeplessness, degradation, suicidal
thinking, and other emotional traumas. Ms. McIntyre loved training as a police
officer and dreams of going into law enforcement again, but knows that she likely
will not be able to do so if she continues to be Brady listed. Ms. McIntyre has

even feared for her life, knowing that if she is in danger and needs police
assistance, she may not be able to call Defendant SPD to respond. Compensation
for Ms. McIntyre’s harms should be determined by a jury at trial.
94.
In the actions and inactions described above and incorporated herein, Defendant
Rappe acted with malice and/or has shown a reckless and outrageous indifference
to a highly unreasonable risk of harm and a conscious indifference to the health,
safety, and welfare of others. Plaintiff is entitled to have a jury determine punitive

damages under ORS 659A.885 in an amount sufficient to deter similar conduct in

the future.
95.
Plaintiff is entitled to reasonable attorney fees and costs under ORS 659A.885.

COMPLAINT – Page 28
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NINTH CLAIM FOR RELIEF – 42 U.S.C. § 1983

VIOLATION OF RIGHT TO INTIMATE ASSOCIATION
(AGAINST DEFENDANT RAPPE)
96.
Plaintiff repeats and realleges paragraphs 1-95 as though fully set forth.
97.
At all times relevant to this complaint, Defendant Rappe was acting individually
and jointly under color of state law with the other defendants and decision-makers
at Defendant SPD, in the scope and course of this duties for Defendant SPD.
98.
Defendant Rappe violated Plaintiff’s right to intimate association and privacy
secured by the First and Fourteenth Amendments to the United States
Constitution by his conduct, including seizing and viewing one or more photos of
Plaintiff, which identified Plaintiff in which her intimate body parts were visible;
inquiring into Plaintiff’s private, off-duty, sexual communications and conduct;

instigating a formal investigation into Plaintiff’s private, off-duty, sexual

communications and conduct; disciplining Plaintiff and restricting her from work
because of her personal, private, beliefs and descriptions of her private, off-duty
sexual interactions; and/or disciplining Plaintiff and restricting her from work

because of private, off-duty, sexual communications and conduct.

99.
Defendant’s actions and inactions have caused Plaintiff harms in an amount to be
determined by a jury at trial, including therapy expenses, wage loss, severe
emotional distress including humiliation, pain, sleeplessness, degradation, suicidal
thinking, and other emotional traumas. Ms. McIntyre loved training as a police
officer and dreams of going into law enforcement again, but knows that she likely
will not be able to do so if she continues to be Brady listed. Ms. McIntyre has
COMPLAINT – Page 29
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even feared for her life, knowing that if she is in danger and needs police
assistance, she may not be able to call Defendant SPD to respond. Compensation
for Ms. McIntyre’s harms should be determined by a jury at trial.
100.
Plaintiff is entitled to reasonable attorney fees, expert fees, and costs under 42
U.S.C. § 1988.

TENTH CLAIM FOR RELIEF – 42 U.S.C. § 1983

FIRST AMENDMENT FREE SPEECH VIOLATION
(AGAINST DEFENDANT RAPPE)
101.
Plaintiff repeats and realleges paragraphs 1-100 as though fully set forth.
102.
At all times relevant to this complaint, Defendant Rappe was acting individually
and jointly under color of state law with the other defendants in the scope and

course of this duties for Defendant SPD.

103.
Defendant Rappe violated Plaintiff’s right to freedom of speech secured by the
First Amendment to the United States Constitution by disciplining Plaintiff,
restricting her from work, and ultimately recommending her termination because

of a statement she made regarding her personal belief regarding a private,

intimate, off-duty sexual experience.
104.
Defendant’s actions and inactions have caused Plaintiff harms in an amount to be
determined by a jury at trial, including therapy expenses, wage loss, severe
emotional distress including humiliation, pain, sleeplessness, degradation, suicidal
thinking, and other emotional traumas. Ms. McIntyre loved training as a police

COMPLAINT – Page 30
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officer and dreams of going into law enforcement again, but knows that she likely
will not be able to do so if she continues to be Brady listed. Ms. McIntyre has
even feared for her life, knowing that if she is in danger and needs police
assistance, she may not be able to call Defendant SPD to respond. Compensation
for Ms. McIntyre’s harms should be determined by a jury at trial.
105.
Plaintiff is entitled to reasonable attorney fees, expert fees, and costs under 42
U.S.C. § 1988.

ELEVENTH CLAIM FOR RELIEF – ORS 659A.030

AIDER AND ABETTOR
(AGAINST DEFENDANT LEWIS)
106.
Plaintiff repeats and realleges paragraphs 1-105 as though fully set forth.
107.

Defendant Lewis violated ORS 659A.030 by aiding, abetting, inciting,

compelling, or coercing Defendant SPD into its discrimination against Plaintiff in
allowing and/or authorizing investigation into Plaintiff’s private, off-duty sexual
conduct because she is a woman; in terminating Plaintiff’s employment because
of private, off-duty sexual conduct when he did not terminate the employment of

comparable men; and/or in making untruthful statements regarding the nature of

her termination in order to protect the men who investigated Plaintiff because she
was a woman.
108.
Defendant’s actions and inactions have caused Plaintiff harms in an amount to be
determined by a jury at trial, including therapy expenses, wage loss, severe
emotional distress including humiliation, pain, sleeplessness, degradation, suicidal

COMPLAINT – Page 31
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thinking, and other emotional traumas. Ms. McIntyre loved training as a police
officer and dreams of going into law enforcement again, but knows that she likely
will not be able to do so if she continues to be Brady listed. Ms. McIntyre has
even feared for her life, knowing that if she is in danger and needs police
assistance, she may not be able to call Defendant SPD to respond. Compensation
for Ms. McIntyre’s harms should be determined by a jury at trial.
109.
In the actions and inactions described above and incorporated herein, Defendant
Rappe acted with malice and/or has shown a reckless and outrageous indifference
to a highly unreasonable risk of harm and a conscious indifference to the health,
safety, and welfare of others. Plaintiff is entitled to have a jury determine punitive

damages under ORS 659A.885 in an amount sufficient to deter similar conduct in

the future.
110.
Plaintiff is entitled to reasonable attorney fees and costs under ORS 659A.885.

TWELFTH CLAIM FOR RELIEF – 42 U.S.C. § 1983

RIGHT TO INTIMATE ASSOCIATION
(AGAINST DEFENDANT LEWIS)
111.

Plaintiff repeats and realleges paragraphs 1-110 as though fully set forth.
112.
At all times relevant to this complaint, Defendant Lewis was acting individually
and jointly under color of state law with the other defendants and decision-makers
at Defendant SPD in the scope and course of this duties for Defendant SPD.

COMPLAINT – Page 32
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113.
Defendant Lewis violated Plaintiff’s right to intimate association and privacy
secured by the First and Fourteenth Amendments to the United States
Constitution by his actions and inactions, including allowing and/or authorizing
investigation into Plaintiff’s private, off-duty sexual conduct; in terminating
Plaintiff’s employment because of private, off-duty sexual conduct; in terminating
Plaintiff’s employment because of her statements regarding private, off-duty
sexual conduct; and/or in asking Defendant Perlow to put Plaintiff on the Lane
County DA’s Brady List.
114.
Defendant’s actions and inactions have caused Plaintiff harms in an amount to be

determined by a jury at trial, including therapy expenses, wage loss, severe

emotional distress including humiliation, pain, sleeplessness, degradation, suicidal
thinking, and other emotional traumas. Ms. McIntyre loved training as a police
officer and dreams of going into law enforcement again, but knows that she likely
will not be able to do so if she continues to be Brady listed. Ms. McIntyre has
even feared for her life, knowing that if she is in danger and needs police
assistance, she may not be able to call Defendant SPD to respond. Compensation
for Ms. McIntyre’s harms should be determined by a jury at trial.

115.
Plaintiff is entitled to reasonable attorney fees, expert fees, and costs under 42
U.S.C. § 1988.

COMPLAINT – Page 33
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THIRTEENTH CLAIM FOR RELIEF – 42 U.S.C. § 1983

FIRST AMENDMENT FREE SPEECH VIOLATION
(AGAINST DEFENDANT LEWIS)
116.
Plaintiff repeats and realleges paragraphs 1-115 as though fully set forth.
117.
At all times relevant to this complaint, Defendant Lewis was acting individually
and jointly under color of state law with the other defendants and decision-makers
at Defendant SPD in the scope and course of this duties for Defendant SPD.
118.
Defendant Lewis violated Plaintiff’s right to freedom of speech secured by the
First Amendment to the United States Constitution by disciplining Plaintiff,
restricting her from work, terminating her because of a statement she made
regarding her personal beliefs about a private, intimate, off-duty sexual
experience, and asking Defendant Perlow to Brady List Plaintiff because of her

statement about private conduct.

119.
Defendant’s actions and inactions have caused Plaintiff harms in an amount to be
determined by a jury at trial, including therapy expenses, wage loss, severe

emotional distress including humiliation, pain, sleeplessness, degradation, suicidal

thinking, and other emotional traumas. Ms. McIntyre loved training as a police
officer and dreams of going into law enforcement again, but knows that she likely
will not be able to do so if she continues to be Brady listed. Ms. McIntyre has
even feared for her life, knowing that if she is in danger and needs police
assistance, she may not be able to call Defendant SPD to respond. Compensation
for Ms. McIntyre’s harms should be determined by a jury at trial.

COMPLAINT – Page 34
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120.
Plaintiff is entitled to reasonable attorney fees, expert fees, and costs under 42
U.S.C. § 1988.

FOURTEENTH CLAIM FOR RELIEF – ORS 659A.030

SEX DISCRIMINATION IN LABOR ORGANIZATION
(AGAINST DEFENDANT POLICE UNION)
121.
Plaintiff repeats and realleges paragraphs 1-120 as though fully set forth.

122.
Defendant Police Union violated ORS 659A.030 by discriminating against and/or
excluding women, including Plaintiff, by interfering with, preventing, or
threatening to prevent discipline against its male members like Defendant
Weaver, who harass and/or commit misconduct against women. In so doing,
Defendant Police Union maintains a membership that excludes women.
123.
Defendant’s actions and inactions have caused Plaintiff harms in an amount to be
determined by a jury at trial, including therapy expenses, wage loss, severe
emotional distress including humiliation, pain, sleeplessness, degradation, suicidal
thinking, and other emotional traumas. Ms. McIntyre loved training as a police
officer and dreams of going into law enforcement again, but knows that she likely
will not be able to do so if she continues to be Brady listed. Ms. McIntyre has
even feared for her life, knowing that if she is in danger and needs police
assistance, she may not be able to call Defendant SPD to respond. Compensation
for Ms. McIntyre’s harms should be determined by a jury at trial.
124.
Plaintiff is entitled to attorney fees under ORS 659A.885.

COMPLAINT – Page 35
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FIFTEENTH CLAIM FOR RELIEF – ORS 659A.030

AIDER AND ABETTOR
(AGAINST DEFENDANT POLICE UNION)
125.
Plaintiff repeats and realleges paragraphs 1-124 as though fully set forth.
126.
Defendant Police Union violated ORS 659A.030 by aiding, abetting, inciting,
compelling, or coercing Defendant SPD into its discrimination against women,
including Plaintiff, in Defendant SPD’s prevention and interference with

discipline against its male members like Defendant Weaver, who harass and/or
commit misconduct against women, and discipline and termination of women,
like Plaintiff.
127.
Defendant’s actions and inactions have caused Plaintiff harms in an amount to be
determined by a jury at trial, including therapy expenses, wage loss, severe
emotional distress including humiliation, pain, sleeplessness, degradation, suicidal
thinking, and other emotional traumas. Ms. McIntyre loved training as a police
officer and dreams of going into law enforcement again, but knows that she likely
will not be able to do so if she continues to be Brady listed. Ms. McIntyre has
even feared for her life, knowing that if she is in danger and needs police
assistance, she may not be able to call Defendant SPD to respond. Compensation
for Ms. McIntyre’s harms should be determined by a jury at trial.
128.
Plaintiff is entitled to attorney fees under ORS 659A.885.

COMPLAINT – Page 36
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SIXTEENTH CLAIM FOR RELIEF - 42 U.S.C. § 1983:

VIOLATION OF FOURTEENTH AMENDMENT DUE PROCESS
(AGAINST DEFENDANTS LEWIS AND PERLOW)
129.
Plaintiff repeats and realleges paragraphs 1-128 as though fully set forth.
130.
At all material times Defendants Lewis and Perlow were acting individually and
jointly under color of state law and within the scope of their employment for
Defendant SPD and the Lane County District Attorney’s Office.
131.
Plaintiff had a protected interest in her reputation, wages, and other benefits
associated with her employment and ability to seek future employment as a law
enforcement officer.
132.
Defendants Lewis and Perlow deprived Plaintiff of her right to procedural due

process secured by the Fourteenth Amendment to the United States Constitution

in recommending she be placed and then placing her on the Lane County District
Attorney’s Office Brady List.
133.

Defendant’s actions and inactions have caused Plaintiff harms in an amount to be

determined by a jury at trial, including therapy expenses, wage loss, severe
emotional distress including humiliation, pain, sleeplessness, degradation, suicidal
thinking, and other emotional traumas. Ms. McIntyre loved training as a police
officer and dreams of going into law enforcement again, but knows that she likely
will not be able to do so if she continues to be Brady listed. Ms. McIntyre has
even feared for her life, knowing that if she is in danger and needs police

COMPLAINT – Page 37
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assistance, she may not be able to call Defendant SPD to respond. Compensation
for Ms. McIntyre’s harms should be determined by a jury at trial.
134.
Under 42 U.S.C. § 1988, Plaintiff is entitled to reasonable attorney fees and costs
to be determined by the court.
135.
In addition to the damages described above, Plaintiff is entitled to an injunctive
order against Defendant Perlow ordering her to remove Plaintiff from the Lane
County District Attorney’s Office Brady List.
/// ///
/// ///

/// ///
/// ///
/// ///
__________________________________
WHEREFORE, Plaintiff Amanda McIntyre prays for judgment against
Defendants as follows:
a. Economic damages for lost wages and medical expenses in an amount
to be determined at trial, and prejudgment interest thereon;

b. Fair and reasonable compensatory damages to be determined at the

time of trial;
c. Punitive damages under ORS 659A.885 and ORS 30.833;
d. Reasonable attorney fees and costs incurred herein under ORS
659A.885, ORS 30.833, ORS 30.863, 42 U.S.C. § 2000e-5, and 42
U.S.C. § 1988; and

COMPLAINT – Page 38
Case 6:21-cv-01709-MK Document 1 Filed 11/27/21 Page 39 of 39

e. An injunctive order against Defendant Perlow ordering her to remove

Plaintiff from the Lane County District Attorney’s Office Brady List.

DATED this 27th day of November, 2021.

______________________________________
Meredith Holley, OSB #125647
Meredith@ErisResolution.com
LAW OFFICE OF MEREDITH HOLLEY
207 E 5th Avenue, Suite 254
Eugene, OR 97401
Telephone: (458) 221-2671
Fax: (833) 352-3615
Attorney for Plaintiff

COMPLAINT – Page 39
 Case 6:21-cv-01709-MK Document 1-1 Filed 11/27/21 Page 1 of 2
JS 44 (Rev. 09/19) CIVIL COVER SHEET
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

I. (a) PLAINTIFFS DEFENDANTS

City of Springfield - Springfield Police Department, Robert Weaver,
Amanda McIntyre Thomas Rappe, Richard Lewis, Springfield Police Association, and
Patricia Perlow
(b) County of Residence of First Listed Plaintiff Lane County of Residence of First Listed Defendant Lane
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
Meredith Holley, Eris Conflict Resolution Alicia M. Wilson, Frohnmayer, Deatherage, Jamieson, Moore,
207 E. 5th Avenue, Suite 254 Armosino & McGovern, PC, Larson Creek Professional Center, 2592
Eugene, OR 97401 Phone: (458) 221-2671 East Barnett Road, Medford, OR 97504, 541-779-2333

II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
’ 1 U.S. Government ’ 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State ’ 1 ’ 1 Incorporated or Principal Place ’ 4 ’ 4
of Business In This State

’ 2 U.S. Government ’ 4 Diversity Citizen of Another State ’ 2 ’ 2 Incorporated and Principal Place ’ 5 ’ 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State

Citizen or Subject of a ’ 3 ’ 3 Foreign Nation ’ 6 ’ 6

Foreign Country
IV. NATURE OF SUIT (Place an “X” in One Box Only) Click here for: Nature of Suit Code Descriptions.
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
’ 110 Insurance PERSONAL INJURY PERSONAL INJURY ’ 625 Drug Related Seizure ’ 422 Appeal 28 USC 158 ’ 375 False Claims Act
’ 120 Marine ’ 310 Airplane ’ 365 Personal Injury - of Property 21 USC 881 ’ 423 Withdrawal ’ 376 Qui Tam (31 USC
’ 130 Miller Act ’ 315 Airplane Product Product Liability ’ 690 Other 28 USC 157 3729(a))
’ 140 Negotiable Instrument Liability ’ 367 Health Care/ ’ 400 State Reapportionment
’ 150 Recovery of Overpayment ’ 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS ’ 410 Antitrust
& Enforcement of Judgment Slander Personal Injury ’ 820 Copyrights ’ 430 Banks and Banking
’ 151 Medicare Act ’ 330 Federal Employers’ Product Liability ’ 830 Patent ’ 450 Commerce
’ 152 Recovery of Defaulted Liability ’ 368 Asbestos Personal ’ 835 Patent - Abbreviated ’ 460 Deportation
Student Loans ’ 340 Marine Injury Product New Drug Application ’ 470 Racketeer Influenced and
(Excludes Veterans) ’ 345 Marine Product Liability ’ 840 Trademark Corrupt Organizations
’ 153 Recovery of Overpayment Liability PERSONAL PROPERTY LABOR SOCIAL SECURITY ’ 480 Consumer Credit
of Veteran’s Benefits ’ 350 Motor Vehicle ’ 370 Other Fraud ’ 710 Fair Labor Standards ’ 861 HIA (1395ff) (15 USC 1681 or 1692)
’ 160 Stockholders’ Suits ’ 355 Motor Vehicle ’ 371 Truth in Lending Act ’ 862 Black Lung (923) ’ 485 Telephone Consumer
’ 190 Other Contract Product Liability ’ 380 Other Personal ’ 720 Labor/Management ’ 863 DIWC/DIWW (405(g)) Protection Act
’ 195 Contract Product Liability ’ 360 Other Personal Property Damage Relations ’ 864 SSID Title XVI ’ 490 Cable/Sat TV
’ 196 Franchise Injury ’ 385 Property Damage ’ 740 Railway Labor Act ’ 865 RSI (405(g)) ’ 850 Securities/Commodities/
’ 362 Personal Injury - Product Liability ’ 751 Family and Medical Exchange
Medical Malpractice Leave Act ’ 890 Other Statutory Actions
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS ’ 790 Other Labor Litigation FEDERAL TAX SUITS ’ 891 Agricultural Acts
’ 210 Land Condemnation ’ 440 Other Civil Rights Habeas Corpus: ’ 791 Employee Retirement ’ 870 Taxes (U.S. Plaintiff ’ 893 Environmental Matters
’ 220 Foreclosure ’ 441 Voting ’ 463 Alien Detainee Income Security Act or Defendant) ’ 895 Freedom of Information
’ 230 Rent Lease & Ejectment ’ 442 Employment ’ 510 Motions to Vacate ’ 871 IRS—Third Party Act
’ 240 Torts to Land ’ 443 Housing/ Sentence 26 USC 7609 ’ 896 Arbitration
’ 245 Tort Product Liability Accommodations ’ 530 General ’ 899 Administrative Procedure
’ 290 All Other Real Property ’ 445 Amer. w/Disabilities - ’ 535 Death Penalty IMMIGRATION Act/Review or Appeal of
Employment Other: ’ 462 Naturalization Application Agency Decision
’ 446 Amer. w/Disabilities - ’ 540 Mandamus & Other ’ 465 Other Immigration ’ 950 Constitutionality of
Other ’ 550 Civil Rights Actions State Statutes
’ 448 Education ’ 555 Prison Condition
’ 560 Civil Detainee -
Conditions of
Confinement
V. ORIGIN (Place an “X” in One Box Only)
’ 1 Original ’ 2 Removed from ’ 3 Remanded from ’ 4 Reinstated or ’ 5 Transferred from ’ 6 Multidistrict ’ 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -
(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
42 USC § 1983, 42 USC 2000e
VI. CAUSE OF ACTION Brief description of cause:
Hostile Work Environment Sexual Harassment, Wrongful Termination, Civil Rights Violations
VII. REQUESTED IN ’ CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P. unspecified JURY DEMAND: ’ Yes ’ No
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
11/27/2021 /s/ Meredith Holley
FOR OFFICE USE ONLY

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

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JS 44 Reverse (Rev. 09/19) Case 6:21-cv-01709-MK Document 1-1 Filed 11/27/21 Page 2 of 2

INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44

Authority For Civil Cover Sheet

The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as
required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is
required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of
Court for each civil complaint filed. The attorney filing a case should complete the form as follows:

I.(a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use
only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and
then the official, giving both name and title.
(b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the
time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land
condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.)
(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting
in this section "(see attachment)".

II. Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place an "X"
in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.
United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.
United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box.
Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment
to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes
precedence, and box 1 or 2 should be marked.
Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the
citizenship of the different parties must be checked. (See Section III below; NOTE: federal question actions take precedence over diversity
cases.)

III. Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this
section for each principal party.

IV. Nature of Suit. Place an "X" in the appropriate box. If there are multiple nature of suit codes associated with the case, pick the nature of suit code
that is most applicable. Click here for: Nature of Suit Code Descriptions.

V. Origin. Place an "X" in one of the seven boxes.

Original Proceedings. (1) Cases which originate in the United States district courts.
Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441.
Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action. Use the date of remand as the filing
date.
Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.
Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or
multidistrict litigation transfers.
Multidistrict Litigation – Transfer. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C.
Section 1407.
Multidistrict Litigation – Direct File. (8) Check this box when a multidistrict case is filed in the same district as the Master MDL docket.
PLEASE NOTE THAT THERE IS NOT AN ORIGIN CODE 7. Origin Code 7 was used for historical records and is no longer relevant due to
changes in statue.

VI. Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional
statutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 Brief Description: Unauthorized reception of cable service

VII. Requested in Complaint. Class Action. Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P.
Demand. In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction.
Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.

VIII. Related Cases. This section of the JS 44 is used to reference related pending cases, if any. If there are related pending cases, insert the docket
numbers and the corresponding judge names for such cases.

Date and Attorney Signature. Date and sign the civil cover sheet.
 Case 6:21-cv-01709-MK Document 1-2 Filed 11/27/21 Page 1 of 10

AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURT

for the
District
__________ of Oregon
District of __________

Amanda McIntyre )
)
)
)
Plaintiff(s) )
)
v. Civil Action No. 6:21-cv-1709
)
CITY OF SPRINGFIELD – SPRINGFIELD POLICE )
DEPARTMENT, ROBERT WEAVER, THOMAS )
RAPPE, RICHARD LEWIS, SPRINGFIELD POLICE )
ASSOCIATION, PATRICIA PERLOW )
Defendant(s) )

SUMMONS IN A CIVIL ACTION

To: (Defendant’s name and address) CITY OF SPRINGFIELD – SPRINGFIELD POLICE DEPARTMENT
230 4th Avenue
Springfield, OR 97477

A lawsuit has been filed against you.

Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are: Law Office of Meredith Holley
207 E. 5th Avenue, Suite 254
Eugene, OR 97401

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT

Date:
Signature of Clerk or Deputy Clerk
 Case 6:21-cv-01709-MK Document 1-2 Filed 11/27/21 Page 2 of 10

AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)

Civil Action No.

PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))

This summons for (name of individual and title, if any)

was received by me on (date) .

’ I personally served the summons on the individual at (place)

on (date) ; or

’ I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date) , and mailed a copy to the individual’s last known address; or

’ I served the summons on (name of individual) , who is

designated by law to accept service of process on behalf of (name of organization)
on (date) ; or

’ I returned the summons unexecuted because ; or

’ Other (specify):
.

My fees are $ for travel and $ for services, for a total of $ 0.00 .

I declare under penalty of perjury that this information is true.

Date:
Server’s signature

Printed name and title

Server’s address

Additional information regarding attempted service, etc:

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 Case 6:21-cv-01709-MK Document 1-2 Filed 11/27/21 Page 3 of 10

AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURT

for the
District
__________ of Oregon
District of __________

Amanda McIntyre )
)
)
)
Plaintiff(s) )
)
v. Civil Action No. 6:21-cv-1709
)
CITY OF SPRINGFIELD – SPRINGFIELD POLICE )
DEPARTMENT, ROBERT WEAVER, THOMAS )
RAPPE, RICHARD LEWIS, SPRINGFIELD POLICE )
ASSOCIATION, PATRICIA PERLOW )
Defendant(s) )

SUMMONS IN A CIVIL ACTION

To: (Defendant’s name and address) ROBERT WEAVER

c/o CITY OF SPRINGFIELD – SPRINGFIELD POLICE DEPARTMENT
230 4th Avenue
Springfield, OR 97477

A lawsuit has been filed against you.

Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are: Law Office of Meredith Holley
207 E. 5th Avenue, Suite 254
Eugene, OR 97401

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT

Date:
Signature of Clerk or Deputy Clerk
 Case 6:21-cv-01709-MK Document 1-2 Filed 11/27/21 Page 4 of 10

AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)

Civil Action No.

PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))

This summons for (name of individual and title, if any)

was received by me on (date) .

’ I personally served the summons on the individual at (place)

on (date) ; or

’ I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date) , and mailed a copy to the individual’s last known address; or

’ I served the summons on (name of individual) , who is

designated by law to accept service of process on behalf of (name of organization)
on (date) ; or

’ I returned the summons unexecuted because ; or

’ Other (specify):
.

My fees are $ for travel and $ for services, for a total of $ 0.00 .

I declare under penalty of perjury that this information is true.

Date:
Server’s signature

Printed name and title

Server’s address

Additional information regarding attempted service, etc:

Print Save As... Reset

 Case 6:21-cv-01709-MK Document 1-2 Filed 11/27/21 Page 5 of 10

AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURT

for the
District
__________ of Oregon
District of __________

Amanda McIntyre )
)
)
)
Plaintiff(s) )
)
v. Civil Action No. 6:21-cv-1709
)
CITY OF SPRINGFIELD – SPRINGFIELD POLICE )
DEPARTMENT, ROBERT WEAVER, THOMAS )
RAPPE, RICHARD LEWIS, SPRINGFIELD POLICE )
ASSOCIATION, PATRICIA PERLOW )
Defendant(s) )

SUMMONS IN A CIVIL ACTION

To: (Defendant’s name and address) THOMAS RAPPE

c/o CITY OF SPRINGFIELD – SPRINGFIELD POLICE DEPARTMENT
230 4th Avenue
Springfield, OR 97477

A lawsuit has been filed against you.

Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are: Law Office of Meredith Holley
207 E. 5th Avenue, Suite 254
Eugene, OR 97401

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT

Date:
Signature of Clerk or Deputy Clerk
 Case 6:21-cv-01709-MK Document 1-2 Filed 11/27/21 Page 6 of 10

AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)

Civil Action No.

PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))

This summons for (name of individual and title, if any)

was received by me on (date) .

’ I personally served the summons on the individual at (place)

on (date) ; or

’ I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date) , and mailed a copy to the individual’s last known address; or

’ I served the summons on (name of individual) , who is

designated by law to accept service of process on behalf of (name of organization)
on (date) ; or

’ I returned the summons unexecuted because ; or

’ Other (specify):
.

My fees are $ for travel and $ for services, for a total of $ 0.00 .

I declare under penalty of perjury that this information is true.

Date:
Server’s signature

Printed name and title

Server’s address

Additional information regarding attempted service, etc:

Print Save As... Reset

 Case 6:21-cv-01709-MK Document 1-2 Filed 11/27/21 Page 7 of 10

AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURT

for the
District
__________ of Oregon
District of __________

Amanda McIntyre )
)
)
)
Plaintiff(s) )
)
v. Civil Action No. 6:21-cv-1709
)
CITY OF SPRINGFIELD – SPRINGFIELD POLICE )
DEPARTMENT, ROBERT WEAVER, THOMAS )
RAPPE, RICHARD LEWIS, SPRINGFIELD POLICE )
ASSOCIATION, PATRICIA PERLOW )
Defendant(s) )

SUMMONS IN A CIVIL ACTION

To: (Defendant’s name and address) SPRINGFIELD POLICE ASSOCIATION

230 4th Avenue
Springfield, OR 97477

A lawsuit has been filed against you.

Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are: Law Office of Meredith Holley
207 E. 5th Avenue, Suite 254
Eugene, OR 97401

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT

Date:
Signature of Clerk or Deputy Clerk
 Case 6:21-cv-01709-MK Document 1-2 Filed 11/27/21 Page 8 of 10

AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)

Civil Action No.

PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))

This summons for (name of individual and title, if any)

was received by me on (date) .

’ I personally served the summons on the individual at (place)

on (date) ; or

’ I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date) , and mailed a copy to the individual’s last known address; or

’ I served the summons on (name of individual) , who is

designated by law to accept service of process on behalf of (name of organization)
on (date) ; or

’ I returned the summons unexecuted because ; or

’ Other (specify):
.

My fees are $ for travel and $ for services, for a total of $ 0.00 .

I declare under penalty of perjury that this information is true.

Date:
Server’s signature

Printed name and title

Server’s address

Additional information regarding attempted service, etc:

Print Save As... Reset

 Case 6:21-cv-01709-MK Document 1-2 Filed 11/27/21 Page 9 of 10

AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURT

for the
District
__________ of Oregon
District of __________

Amanda McIntyre )
)
)
)
Plaintiff(s) )
)
v. Civil Action No. 6:21-cv-1709
)
CITY OF SPRINGFIELD – SPRINGFIELD POLICE )
DEPARTMENT, ROBERT WEAVER, THOMAS )
RAPPE, RICHARD LEWIS, SPRINGFIELD POLICE )
ASSOCIATION, PATRICIA PERLOW )
Defendant(s) )

SUMMONS IN A CIVIL ACTION

To: (Defendant’s name and address) PATRICIA PERLOW

Lane County District Attorney's Office
125 E 8th Avenue #400
Eugene, OR 97401

A lawsuit has been filed against you.

Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are: Law Office of Meredith Holley
207 E. 5th Avenue, Suite 254
Eugene, OR 97401

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT

Date:
Signature of Clerk or Deputy Clerk
 Case 6:21-cv-01709-MK Document 1-2 Filed 11/27/21 Page 10 of 10

AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)

Civil Action No.

PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))

This summons for (name of individual and title, if any)

was received by me on (date) .

’ I personally served the summons on the individual at (place)

on (date) ; or

’ I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date) , and mailed a copy to the individual’s last known address; or

’ I served the summons on (name of individual) , who is

designated by law to accept service of process on behalf of (name of organization)
on (date) ; or

’ I returned the summons unexecuted because ; or

’ Other (specify):
.

My fees are $ for travel and $ for services, for a total of $ 0.00 .

I declare under penalty of perjury that this information is true.

Date:
Server’s signature

Printed name and title

Server’s address

Additional information regarding attempted service, etc:

Print Save As... Reset