IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF MULTNOMAH. Case No.: ) ) ) ) ) ) ) ) ) ) ) ) )

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1 // :1: PM CV JESSICA L. STRADLEY, vs. IN THE CIRCUIT COURT OF THE STATE OF OREGON Plaintiff, CITY OF PORTLAND, a Municipal corporation; PATRICK MAWDSLEY, an individual; and MATTHEW GINNOW, an individual, Defendants FOR THE COUNTY OF MULTNOMAH Case No.: Plaintiff demands a jury trial and alleges: COMPLAINT FOR ASSAULT, BATTERY AND (NOT SUBJECT TO MANDATORY ARBITRATION JURY TRIAL DEMANDED PRAYER: $1,00 ORS.0(1(c FOR A FIRST CLAIM FOR RELIEF FOR BATTERY AGAINST DEFENDANT CITY OF PORTLAND, plaintiff alleges: 1. Defendant City of Portland is and at all times mentioned herein has been a municipal corporation in the State of Oregon.. Notice of this claim was properly given to the City of Portland within 0 days of the incident. PAGE 1 COMPLAINT FOR ASSAULT, BATTERY AND SW Second Ave., Ste.0 Portland, OR Fax: 0-- Phone: 0--

2 1 1 PAGE COMPLAINT FOR ASSAULT, BATTERY AND. All conduct of all Portland Police officers alleged herein was done within the scope of their employment as Portland Police officers.. On or about August,, plaintiff Jessica Stradley accompanied her husband, Cory, and her six year old daughter to a private home in Boring, Oregon, where a wedding involving a groom who is a member of the Portland Police Bureau was being held.. At the above time and place, a large number of Portland Police officers were in attendance and virtually all of them had been drinking alcohol for a number of hours prior to the incident described herein.. Late in the above-described evening, one of the wives of one of the Portland Police officers accused plaintiff of attempting to steal her wallet, and plaintiff explained that the wallet sticking out of her purse had obviously been placed there by accident. At that time, plaintiff put the item on the table and plaintiff and her husband were immediately attacked by a number of Portland Police officers, including Officers Patrick Mawdsley and Matthew Ginnow.. For some reason, one of the officers incorrectly told plaintiff and her husband that they were a bunch of fucking Russians, and when Cory Stradley replied that it was ridiculous to think that anyone would try to steal a SW Second Ave., Ste.0 Portland, OR Fax: 0-- Phone: 0--

3 1 1 purse at a police wedding, one of the police officers grabbed Jessica Stradley and began shaking her, and another officer rushed at plaintiff Jessica Stradley from behind, knocking her off her feet and into another officer, who shoved her to the ground. PAGE COMPLAINT FOR ASSAULT, BATTERY AND. One of the officers then held Jessica Stradley down with one hand across her throat, saying, I m going to fucking kill you. He was applying pressure to her windpipe.. When Ms. Stradley was finally able to get on her feet, she was again pushed from behind by another officer, striking her head on a pole which had been set up to accommodate lighting, and she suffered a cut wound on her head. As she then tried to walk away, one of the officers pulled down on her strapless dress, exposing her down to her waist.. As she was leaving with her husband and daughter, Ms. Stradley declared that she was going to call the police, and one of the officers replied, Go ahead and call the fucking police. We are the police.. As Cory Stradley was seeking to get the names of the officers involved from the various officers at the scene, none of them would give any information. One of the officers then said, Go ahead and call Clackamas County, I ll tell them that your wife punched me in the face. Who do you think SW Second Ave., Ste.0 Portland, OR Fax: 0-- Phone: 0--

4 1 1 they re going to believe, you guys, or a bunch of cops? Another officer said, We know Clackamas County deputy sheriffs, we know lots of them, and they ll be happy to come down and do a report. 1. The acts of all officers described herein, including officers Patrick Mawdsley and Matthew Ginnow, constituted a common venture, and all actions of all officers described herein was done in concert with other officers for the purposes of causing harm and humiliation to plaintiff. 1. As a result of the above-described battery, plaintiff suffered, continues to suffer, and may permanently suffer from pain, humiliation, indignity, fear, intrusive thoughts, heightened vigilance, symptoms of brain injury, bruising and battering injuries about her body, injury to her left shoulder, cortisone injections, headaches, photophobia, short-term memory loss, neck injury, nightmares, anxiety, fear of police and pain and suffering all to her noneconomic damages in the amount of $00,000.. As a further result of the above-described battery, plaintiff has been required to incur $,00 in medical expenses, and in the future will incur medical care in the reasonable value of $,000. // PAGE COMPLAINT FOR ASSAULT, BATTERY AND SW Second Ave., Ste.0 Portland, OR Fax: 0-- Phone: 0--

5 1 1 FOR A SECOND CLAIM FOR RELIEF FOR BATTERY AGAINST DEFENDANTS PATRICK MAWDSLEY AND MATTHEW GINNOW, plaintiff alleges:. In alternative to the first claim for relief, the acts of officers described herein was not in the scope of their employment.. Plaintiff re-alleges and incorporates by reference the first claim for relief, with the exception of paragraph. WHEREFORE, plaintiff prays for judgment against defendant City of Portland and Officers Patrick Mawdsley and Matthew Ginnow in the amount of $00,000 in noneconomic damages, $1,00 in economic damages, and for her costs and disbursements necessarily incurred herein. Dated: April,. /s/ Gregory Kafoury Gregory Kafoury, OSB # Kafoury@kafourymcdougal.com Mark McDougal, OSB #0 mcdougal@kafourymcdougal.com Jason Kafoury, OSB #0 jkafoury@kafourymcdougal.com Attorneys for Plaintiff PAGE COMPLAINT FOR ASSAULT, BATTERY AND SW Second Ave., Ste.0 Portland, OR Fax: 0-- Phone: 0--