2/13/ :36 PM 19CV07131 IN THE CIRCUIT COURT FOR THE STATE OF OREGON FOR MULTNOMAH COUNTY. Case No. COMPLAINT. Negligence FACTUAL ALLEGATIONS

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1 //0 : PM CV0 IN THE CIRCUIT COURT FOR THE STATE OF OREGON FOR MULTNOMAH COUNTY 0 AMBER HARRISON Plaintiff vs MCDONALD S CORPORATION Defendant. Case No. COMPLAINT Negligence Not Subject to Mandatory Arbitration Amount in Controversy: $0,000 Filing Fee Authority: ORS.0()(a) 0 FACTUAL ALLEGATIONS Ms. Harrison has worked at McDonalds for the past two years. Throughout the last year, McDonalds management has sat idly by and watched as Ms. Harrison has been repeatedly assaulted, beaten, belittled, taunted, harassed and made fun of by a co-worker. Over the past year while working at McDonalds Ms. Harrison has been repeatedly kicked, hit, and bullied. Ms. Harrison has complained about the coworker s abusive behavior but McDonalds management says her co-worker is too valuable to the company to fire. COMPLAINT Page of

2 . Last week the co-worker fashioned an improvised image of a McPenis and stuck it to Ms. Harrison s back while she was working, then followed Ms. Harrison around the workplace and teased her with the image. When Ms. Harrison found out the image had been stuck to her she immediately called her grandmother from work crying uncontrollably. 0 0 COMPLAINT Page of

3 0 0. CAUSE OF ACTION Negligence At all times in the past year McDonalds operated the restaurant in South Salem, Oregon where Ms. Harrison was injured. At all times McDonalds employed the co-worker that injured Ms. Harrison. At all times McDonalds maintained regular and sustained business in Multnomah County, Oregon.. McDonalds had a duty to maintain its workplace in a safe and suitable condition for the employees under its supervision. By inviting Ms. Harrison to join its workforce, McDonalds accepted responsibility to keep Ms. Harrison safe in its workplace. McDonalds knew and should have known Ms. Harrison would sustain injuries if it hired abusive co-workers and failed to properly supervise abusive coworkers, and failed to properly terminate abusive co-workers. McDonalds and Ms. Harrison were in a special relationship of employer to employee, and Ms. Harrison trusted McDonalds to maintain a safe and suitable workplace and McDonalds had a special duty to assure Ms. Harrison s safety while she was working at McDonalds s restaurant. COMPLAINT Page of

4 0. Ms. Harrison s injuries were due in whole or in part to the acts and omissions of McDonalds, which was negligent in one or more respects: a. In failing to exercise reasonable care over its restaurant b. In failing to properly screen Ms. Harrison s co-worker for employment c. In failing to properly supervise Ms. Harrison s co-worker d. In failing to properly terminate Ms. Harrison s co-worker e. In failing to adopt policies necessary to protect Ms. Harrison s safety 0. As a direct result of McDonalds s negligent acts and omissions as alleged in this complaint, Ms. Harrison experienced injuries and harm, all of which were reasonably foreseeable, including uncontrolled crying, distress and discomfort. Ms. Harrison requests fair compensation for her harm in an amount to be determined by the jury to be reasonable, but not to exceed $0,000. Ms. Harrison also requests an order declaring that McDonalds s behavior as alleged in this complaint was negligent in one or more regards, costs and disbursements, and maximum pre and post judgment interest. Ms. Harrison reserves the right to amend this complaint to adjust her request for compensation as well as to add additional defendants and new claims, including a claim for punitive damages, as new information is learned in discovery. COMPLAINT Page of

5 . PRAYER FOR RELIEF Ms. Harrison respectfully requests relief as sought in paragraph and any other relief the Court may deem appropriate. 0. REQUEST FOR JURY TRIAL Ms. Harrison respectfully requests a trial by a jury. 0 February, 0 RESPECTFULLY FILED, /s/ Michael Fuller Michael Fuller, OSB No. 0 Lead Trial Attorney for Ms. Harrison OlsenDaines US Bancorp Tower SW th Ave., Suite 0 Portland, Oregon 0 michael@underdoglawyer.com Direct Kelly Jones, OSB No. 0 Of Attorneys for Ms. Harrison The Law Office of Kelly Jones kellydonovanjones@gmail.com COMPLAINT Page of