NINETEENTH CLAIM FOR RELIEFBy Plaintiff BPO Against All Defendants
Intentional Infliction of Emotional Distress102.[/list]
Plaintiff BPO realleges and incorporates by reference paragraphs 1 through 11, above.
103.[/list]
Defendants formed a special relationship with Plaintiff BPO by soliciting him and/or his parents to attend their "therapeutic boarding school," accepting him as a resident, and closely governing his conduct there. Defendants assumed
in loco parentis responsibility for Plaintiff BPO's well-being, took charge of every aspect of Plaintiff BPO's life, and eliminated virtually all of BPO's interaction with the outside world. At the same time, Defendants ostensibly were instructing him on his emotional and psychological condition, assisting him in changing his behavior, and claiming to provide standard educational services. In doing so, Defendants' relationship with Plaintiff BPO included a specific duty to avoid the infliction of emotional distress.
104.[/list]
Defendants' counselors and other agents, using the Program described in paragraphs 6 through 8, above, knowingly and intentionally caused severe emotional distress to Plaintiff BPO when they physically and psychologically abused him through the program. Defendants also refused to allow Plaintiff BPO unmonitored contact with his family, and would end calls or destroy letters if Plaintiff BPO attempted to tell his family what was occurring. During all seven on-campus "Lifestep" group encounters (some lasting for several days without interruption), Defendants forced Plaintiff BPO to endure temperature extremes, meal deprivation, sleep deprivation, denial of restroom use, and rotted food, as well as denigrating, cruel, and abusive shouting at Plaintiff BPO. For instance, Plaintiff BPO was forced to hike and camp in sub-zero temperatures during a ten day wilderness event. BPO was also punished as were the others with social isolation for periods of days and weeks during which times he was forced to perform punitive labor such as being required to dig into a frozen hillside. In the course of one of the seven on-campus "Lifestep" encounter groups, Plaintiff BPO was forced to hit a mattress until his knuckles bled. This list of abusive acts is not exclusive.
105.[/list]
Plaintiff BPO did in fact suffer severe emotional distress as a result of this abuse that occurred as part of the Program, and such physical and psychological abuse of a child is beyond the bounds of all socially tolerable conduct.
106.[/list]
Defendants' counselors used the Program described in paragraphs 6 through 8, above, to intentionally inflict severe emotional distress through the abuse of Plaintiff BPO. Defendants' Program was administered by their counselors within the course and scope of the counselors' agency as described in paragraphs 9 and 10, above.
107.[/list]
As a result of Defendants' intentional infliction of emotional distress, Plaintiff BPO has suffered permanent and lasting damages including bodily harm at the time of abuse, severe physical, mental, and emotional harm at the time of the abuse, as well as later-manifesting and/or later-arising permanent psychological damage that was distinct in time and logic from what was suffered at the time of the abuse. These harms resulted in Plaintiff BPO's non-economic damages in the amount of $1,000,000.00, the exact amount of which will be proven at the time of trial.
108.[/list]
As a result of Defendants' intentional infliction of emotional distress, Plaintiff BPO has incurred and/or will incur in the future costs for counseling, psychiatric, psychological, and medical treatment. Plaintiff BPO has also suffered lost economic opportunity for the interruption of his studies. Plaintiff BPO's economic damages total the approximate amount of $500,000.00, the exact amount of which will be proven at the time of trial.
TWENTIETH CLAIM FOR RELIEFBy Plaintiff BPO Against All Defendants
Negligent Infliction of Emotional Distress109.[/list]
Plaintiff BPO realleges and incorporates by reference paragraphs 1 through 11, and 102 through 108, above.
110.[/list]
Defendants, acting within their special relationship, subjected Plaintiff BPO to severe ridicule, harsh and unnecessary disciplinary measures, and denial of an education, as described above. Additionally, as part of the Program, Defendants' counselors would engage in denigrating, cruel, and abusive berating of Plaintiff BPO, frequently yelling at him, mocking him harshly and requiring other residents do so, and yelling at him that he was worthless. Defendants also required Plaintiff BPO to submit to being observed while naked and getting dressed.
111.[/list]
Defendants' administration of the Program was an intentional or reckless disregard of Plaintiff's feelings while in this responsible relationship. Defendants brutally invaded Plaintiff BPO's protected interest in his privacy, emotional health, and psychological well-being, and this invasion was of a sufficient quality or magnitude to warrant recovery of emotional distress damages. As a result of this, Plaintiff suffered the damages described in paragraphs 107 and 108, above.
TWENTY-FIRST CLAIM FOR RELIEFBy Plaintiff BPO Against All Defendants
Battery112.[/list]
Plaintiff BPO realleges and incorporates by reference paragraphs 1 through 11, and 102 through 111, above.
113.[/list]
During the various "Lifestep" group encounters, Defendants controlled the physical conduct of all of the residents and counselors, and directed, coerced, or required both other residents and staff to physically batter Plaintiff BPO as part of the "Lifestep" program. Other residents were forced under duress to participate by threat of severe punishments if they did not appear to be participating fully in the physical assaults on their peers.
114.[/list]
Specifically, during one "Lifestep," individual residents—including Plaintiff BPO—were required to "break into" a circle of other residents by running at the circle at high speed and physically fighting to gain entry while those in the circle linked arms and fought under the orders of Defendants to prevent entry. In the course of this activity, both individual residents and those who were trying to break in sustained significant physical injuries. Plaintiff BPO suffered injuries both as the individual breaking in and as one of the members of the circle. In another "Lifestep," Defendants ordered Plaintiff BPO to rip out of a bedsheet that was forcibly being held down by other residents. While being held under this sheet and trying to rip through it, Plaintiff BPO sustained numerous painful abrasions and fabric burns as well as feelings of claustrophobia and helplessness.
115.[/list]
The "breaking into" the circle and defending it from other residents, as well as being held under a sheet, constituted harmful and offensive touching to which Plaintiff BPO did not and could not consent. At all times relevant to this complaint, the persons who battered Plaintiff BPO were acting under the forced compulsion or directions of Defendants.
116.[/list]
As a result of this physical battery at the orders of Defendants, Plaintiff BPO suffered the damages described in paragraphs 107 and 108, above.
TWENTY-SECOND CLAIM FOR RELIEFBy Plaintiff NCQ Against All Defendants
Intentional Infliction of Emotional Distress117.[/list]
Plaintiff NCQ realleges and incorporates by reference paragraphs 1 through 11, above.
118.[/list]
Defendants formed a special relationship with Plaintiff NCQ by soliciting him and/or his parents to attend their "therapeutic boarding school," accepting him as a resident, and closely governing his conduct there. Defendants assumed
in loco parentis responsibility for Plaintiff NCQ's well-being, took charge of every aspect of Plaintiff NCQ's life, and eliminated virtually all of NCQ's interaction with the outside world. At the same time, Defendants ostensibly were instructing him on his emotional and psychological condition, assisting him in changing his behavior, and claiming to provide standard educational services. In doing so, Defendants' relationship with Plaintiff NCQ included a specific duty to avoid the infliction of emotional distress.
119.[/list]
Defendants' counselors and other agents, using the Program described in paragraphs 6 through 8, above, knowingly and intentionally caused severe emotional distress to Plaintiff NCQ when they physically and psychologically abused him through the program. Defendants also refused to allow Plaintiff NCQ unmonitored contact with his family, and would end calls or destroy letters if Plaintiff NCQ attempted to tell his family what was occurring. During all seven on-campus "Lifestep" group encounters (some lasting for several days without interruption), Defendants forced Plaintiff NCQ to endure temperature extremes, meal deprivation, sleep deprivation, denial of restroom use, and rotted food, as well as denigrating, cruel, and abusive shouting at Plaintiff NCQ. For instance, during one "Lifestep" that occurred while camping, Defendants forced Plaintiff NCQ to eat pita bread with one-inch growths of mold on it. In retaliation for Plaintiff NCQ passing out flyers about "brainwashing" at Mt. Bachelor Academy, Defendants had Plaintiff NCQ committed to a mental hospital, and demanded he renounce the contents of the flyers or not be allowed to see any of his friends at Mt. Bachelor Academy again. When Plaintiff NCQ tore his meniscus while snowboarding at Mt. Bachelor Academy, Defendants refused to allow him any medical care. Plaintiff NCQ also developed severe tendinitis as a result of the forced running during various disciplinary punishments, but was refused medical care and required to continue running despite the injury. This list of abusive acts is not exclusive.
120.[/list]
Plaintiff NCQ did in fact suffer severe emotional distress as a result of this abuse that occurred as part of the Program, and such physical and psychological abuse of a child is beyond the bounds of all socially tolerable conduct.
121.[/list]
Defendants' counselors used the Program described in paragraphs 6 through 8, above, to intentionally inflict severe emotional distress through the abuse of Plaintiff NCQ. Defendants' Program was administered by their counselors within the course and scope of the counselors' agency as described in paragraphs 9 and 10, above.
122.[/list]
As a result of Defendants' intentional infliction of emotional distress, Plaintiff NCQ has suffered permanent and lasting damages including bodily harm at the time of abuse, severe physical, mental, and emotional harm at the time of the abuse, as well as later-manifesting and/or later-arising permanent psychological damage that was distinct in time and logic from what was suffered at the time of the abuse. These harms resulted in Plaintiff NCQ's non-economic damages in the amount of $1,000,000.00, the exact amount of which will be proven at the time of trial.
123.[/list]
As a result of Defendants' intentional infliction of emotional distress, Plaintiff NCQ has incurred and/or will incur in the future costs for counseling, psychiatric, psychological, and medical treatment. Plaintiff NCQ has also suffered lost economic opportunity for the interruption of his studies. Plaintiff NCQ's economic damages total the approximate amount of $500,000.00, the exact amount of which will be proven at the time of trial.
TWENTY-THIRD CLAIM FOR RELIEFBy Plaintiff NCQ Against All Defendants
Negligent Infliction of Emotional Distress124.[/list]
Plaintiff NCQ realleges and incorporates by reference paragraphs 1 through 11, and 117 through 123, above.
125.[/list]
Defendants, acting within their special relationship, subjected Plaintiff NCQ to severe ridicule, harsh and unnecessary disciplinary measures, and denial of an education, as described above. Additionally, as part of the Program, Defendants' counselors would engage in denigrating, cruel, and abusive berating of Plaintiff NCQ, frequently yelling at him, mocking him harshly and requiring other residents do so, and yelling at him that he was worthless. Defendants also required Plaintiff NCQ to submit to being observed while naked and getting dressed. Additionally, Defendants refused to allow Plaintiff NCQ to return home when his mother began to die; she died while he was on an airplane after Defendants eventually permitted the return.
126.[/list]
Defendants administration of the Program was an intentional or reckless disregard of Plaintiff's feeling while in this responsible relationship. Defendants brutally invaded Plaintiff NCQ's protected interest in his privacy, emotional health, and psychological well-being, and this invasion was of a sufficient quality or magnitude to warrant recovery of emotional distress damages. As a result of this, Plaintiff suffered the damages described in paragraphs 122 and 123, above.
TWENTY-FOURTH CLAIM FOR RELIEFBy Plaintiff NCQ Against All Defendants
Battery127.[/list]
Plaintiff NCQ realleges and incorporates by reference paragraphs 1 through 11, and 117 through 126, above.
128.[/list]
During the various "Lifestep" group encounters, Defendants controlled the physical conduct of all of the residents and counselors, and directed, coerced, or required both other residents and staff to physically batter Plaintiff NCQ as part of the "Lifestep" program. Other residents were forced under duress to participate by threat of severe punishments if they did not appear to be participating fully in the physical assaults on their peers.
129.[/list]
Specifically, during one "Lifestep," individual residents—including Plaintiff NCQ—were required to "break into" a circle of other residents by running at the circle at high speed and physically fighting to gain entry while those in the circle linked arms and fought under the orders of Defendants to prevent entry. In the course of this activity, both individual residents and those who were trying to break in sustained significant physical injuries. Plaintiff NCQ suffered injuries both as the individual breaking in and as one of the members of the circle. In another "Lifestep," Defendants ordered Plaintiff NCQ to rip out of a bedsheet that was forcibly being held down by other residents. While being held under this sheet and trying to rip through it, Plaintiff NCQ sustained numerous painful abrasions and fabric burns as well as feelings of claustrophobia and helplessness.
130.[/list]
the "breaking into" the circle and defending it from other residents, as well as being held under a sheet, constituted harmful and offensive touching to which Plaintiff NCQ did not and could not consent. At all times relevant to this complaint, the persons who battered Plaintiff NCQ were acting under the forced compulsion or directions of Defendants.
131.[/list]
*******
As a result of this physical battery at the orders of Defendants, Plaintiff NCQ suffered the damages described in paragraphs 77 and 78, above.
TWENTY-FIFTH CLAIM FOR RELIEFBy Plaintiff WBL Against All Defendants
Intentional Infliction of Emotional Distress132.[/list]
Plaintiff WBL realleges and incorporates by reference paragraphs 1 through 11, above.
133.[/list]
Defendants formed a special relationship with Plaintiff WBL by soliciting him and/or his parents to attend their "therapeutic boarding school," accepting him as a resident, and closely governing his conduct there. Defendants assumed
in loco parentis responsibility for Plaintiff WBL's well-being, took charge of every aspect of Plaintiff WBL's life, and eliminated virtually all of WBL's interaction with the outside world. At the same time, Defendants ostensibly were instructing him on his emotional and psychological condition, assisting him in changing his behavior, and claiming to provide standard educational services. In doing so, Defendants' relationship with Plaintiff WBL included a specific duty to avoid the infliction of emotional distress.
134.[/list]
Defendants' counselors and other agents, using the Program described in paragraphs 6 through 8, above, knowingly and intentionally caused severe emotional distress to Plaintiff WBL when they physically and psychologically abused him through the program. Defendants also refused to allow Plaintiff WBL unmonitored contact with his family, and would end calls or destroy letters if Plaintiff WBL attempted to tell his family what was occurring. During all seven on-campus "Lifestep" group encounters (some lasting for several days without interruption), Defendants forced Plaintiff WBL to endure temperature extremes, meal deprivation, sleep deprivation, denial of restroom use, and rotted food, as well as denigrating, cruel, and abusive shouting at Plaintiff WBL. For instance, in the course of one of the seven on-campus "Lifestep" encounter groups, Plaintiff WBL was forced to hit a mattress until his knuckles bled; he still has scarring on his knuckles from that activity. In another "Lifestep" encounter group, Plaintiff was required to verbally attack his mother and blame her for his problems for approximately eight hours—while being deprived of food, water, restroom use, and sleep, and subjected to the song "Mother" played at extremely high volume for the entire eight hours—despite the fact that Plaintiff WBL's parents had both died years before in separate events. Plaintiff WBL alleges that discovery will show that Mt. Bachelor Academy knew of his mother being dead, and still required Plaintiff WBL to go through this "Lifestep." Plaintiff WBL is diabetic, and Defendants refused him access to his insulin, refused him access to food, and forced WBL to stay in the woods alone without his insulin, bringing it to him only in the morning and at night.
135.[/list]
Plaintiff WBL did in fact suffer severe emotional distress as a result of this abuse that occurred as part of the Program, and such physical and psychological abuse of a child is beyond the bounds of all socially tolerable conduct.
136.[/list]
Defendants' counselors used the Program described in paragraphs 6 through 8, above, to intentionally inflict severe emotional distress through the abuse of Plaintiff WBL. Defendants' Program was administered by their counselors within the course and scope of the counselors' agency as described in paragraphs 9 and 10, above.
137.[/list]
As a result of Defendants' intentional infliction of emotional distress, Plaintiff WBL has suffered permanent and lasting damages including bodily harm at the time of abuse, severe physical, mental, and emotional harm at the time of the abuse, as well as later-manifesting and/or later-arising permanent psychological damage that was distinct in time and logic from what was suffered at the time of the abuse. These harms resulted in Plaintiff WBL's non-economic damages in the amount of $1,000,000.00, the exact amount of which will be proven at the time of trial.
138.[/list]
As a result of Defendants' intentional infliction of emotional distress, Plaintiff WBL has incurred and/or will incur in the future costs for counseling, psychiatric, psychological, and medical treatment. Plaintiff WBL has also suffered lost economic opportunity for the interruption of his studies. Plaintiff WBL's economic damages total the approximate amount of $500,000.00, the exact amount of which will be proven at the time of trial.
TWENTY-SIXTH CLAIM FOR RELIEFBy Plaintiff WBL Against All Defendants
Negligent Infliction of Emotional Distress139.[/list]
Plaintiff WBL realleges and incorporates by reference paragraphs 1 through 11, and 132 through 138, above.
140.[/list]
Defendants, acting within their special relationship, subjected Plaintiff WBL to severe ridicule, harsh and unnecessary disciplinary measures, and denial of an education, as described above. Additionally, as part of the Program, Defendants' counselors would engage in denigrating, cruel, and abusive berating of Plaintiff WBL, frequently yelling at him, mocking him harshly and requiring other residents do so, and yelling at him that he was worthless. Defendants also required Plaintiff WBL to submit to being observed while naked and getting dressed. On one occasion, one of the Mt. Bachelor Academy staff exposed himself to Plaintiff WBL. In the alternative to the allegation in paragraph 94 that Defendants knew of Plaintiff's mother's death prior to the "Lifestep" in which he was forced to attack her
in absentia, Defendants should have known of this, and Plaintiff suffered significant psychological trauma (apart from the physical trauma of the ordeal) of having to vilify his recently-deceased mother.
141.[/list]
Defendants' administration of the Program was an intentional or reckless disregard of Plaintiff's feelings while in this responsible relationship. Defendants brutally invaded Plaintiff WBL's protected interest in his privacy, emotional health, and psychological well-being, and this invasion was of a sufficient quality or magnitude to warrant recovery of emotional distress damages. As a result of this, Plaintiff suffered the damages described in paragraphs 137 and 138, above.
TWENTY-SEVENTH CLAIM FOR RELIEFBy Plaintiff WBL Against All Defendants
Battery142.[/list]
Plaintiff WBL realleges and incorporates by reference paragraphs 1 through 11, and 132 through 141, above.
143.[/list]
During the various "Lifestep" group encounters, Defendants controlled the physical conduct of all of the residents and counselors, and directed, coerced, or required both other residents and staff to physically batter Plaintiff WBL as part of the "Lifestep" program. Other residents were forced under duress to participate by threat of severe punishments if they did not appear to be participating fully in the physical assaults on their peers.
144.[/list]
Specifically, during one "Lifestep," individual residents—including Plaintiff WBL—were required to "break into" a circle of other residents by running at the circle at high speed and physically fighting to gain entry while those in the circle linked arms and fought under the orders of Defendants to prevent entry. In the course of this activity, both individual residents and those who were trying to break in sustained significant physical injuries. Plaintiff WBL suffered injuries both as the the individual breaking in and as one of the members of the circle. In another "Lifestep," Defendants ordered Plaintiff WBL to rip out of a bedsheet that was forcibly being held down by other residents. While being held under this sheet and trying to rip through it, Plaintiff WBL sustained numerous painful abrasions and fabric burns as well as feelings of claustrophobia and helplessness.
145.[/list]
The "breaking into" the circle and defending it from other residents, as well as being held under a sheet, constituted harmful and offensive touching to which Plaintiff WBL did not and could not consent. At all times relevant to this complaint, the persons who battered Plaintiff WBL were acting under the forced compulsion or directions of Defendants.
146.[/list]
As a result of this physical battery at the orders of Defendants, Plaintiff WBL suffered the damages described in paragraphs 137 and 138, above.
TWENTY-EIGHTH CLAIM FOR RELIEFBy All Plaintiffs Against All Defendants
Negligence147.[/list]
Plaintiffs reallege and incorporate by reference paragraphs 1 through 146, above.
148.[/list]
At all times relevant to this complaint, Defendants had a special relationship with all of these Plaintiffs by virtue of Defendants' role as a residential boarding school, their control over the lives of Plaintiffs, and their near-total elimination of all of Plaintiffs' contacts with the outside world. Defendants also had full control over the actions of Defendants' counselors while they performed their employment duties on behalf of Defendants. This special relationship created a duty of care on the part of Defendants to ensure Plaintiffs' safety while participating in Defendants' Program or interacting with Defendants' agents.
149.[/list]
Defendants knew that children were suffering physical and mental abuse in the Program run by Defendants' counselors, and that several children had gone so far as to kill themselves in the course of the Program, specifically because of the Program. Defendant created and maintained this Program, employed the counselors, and retained their exclusive right to control every aspect of the Program and the actions of the counselors within that Program.
150.[/list]
Defendants knew of the danger that they had created with the Program and/or given their special
in loco parentis relationship with Plaintiffs, yet Defendants did nothing to change the substance or format of the program in any respect while Plaintiffs resided at Mt. Bachelor Academy. In fact, the Program
was institutionalized/ritualized abuse. Thus, it was foreseeable—in fact certain—that unless Defendants changed the Program, children would continue to be physcially and mentally abused. Alternatively, Defendants knew that the manner in which their minimally educated and untrained counselors conducted the Program caused physical and mental injury to children, yet failed to more closely supervise and train their counselors to avoid such injuries. It was therefore foreseeable that the refusal or failure to better train and supervise their employees would result in continued abuse of children.
151.[/list]
Knowing of the risks of physical and mental injury posed by the Program and/or the counselors' running of the Program, it was unreasonable for Defendants to fail to alter the nature of the program or more closely supervise and train their agents and employees.
152.[/list]
Plaintiffs have a right to be free from physical and mental abuse at the hands of Defendants' agents. Plaintiffs were all residents at Mt. Bachelor Academy, and thus were within the class of persons to be protected by Defendants' proper operation of their Program.
153.[/list]
All of the damages suffered by Plaintiffs, as described above, were caused by Defendants' refusal or failure to correct the known risks to Plaintiffs' health, safety, and mental health posed by Defendants' running of the Program. But for Defendants' program, these Plaintiffs would not have been subjected to the "Lifesteps" or the harsh and cruel discipline that Defendants inflicted upon Plaintiffs.
154.[/list]
As a direct and foreseeable result of Defendants' refusal or failure to correct the problems in the Program, each of the Plaintiffs suffered the abuses described above and incurred the respective damages described above in the Plaintiffs' individual claims for relief.
155.[/list]
Plaintiffs here provide notice that at any time after the filing of this complaint, Plaintiffs intend to move for punitive damages against the Defendants pursuant to ORS 31.725.
WHEREFORE, Plaintiffs pray for judgment against Defendants, and each of them, as follows:
1. If successful on the First, Second, or Third Claims for Relief, non-economic damages for Plaintiff MLM in the amount of $1,000,000.00, the exact amount to be determined by the jury at the time of trial;
2. If successful on the First, Second, or Third Claims for Relief, Economic damages for Plaintiff MLM in the amount of $500,000.00, the exact amount to be determined by the jury at the time of trial;
3. If successful on the Fourth, Fifth, or Sixth Claims for Relief, non-economic damages for Plaintiff NAA in the amount of $1,000,000.00, the exact amount to be determined by the jury at the time of trial;
4. If successful on the Fourth, Fifth, or Sixth Claims for Relief, economic damages for Plaintiff NAA in the amount of $750,000.00, the exact amount to be determined by the jury at the time trial;
5. If successful on the Seventh, Eighth, or Ninth Claims for Relief, non-economic damages for Plaintiff TGB in the amount of $1,000,000.00, the exact amount to be determined by the jury at the time of trial;
6. If successful on the Seventh, Eighth, or Ninth Claims for Relief, economic damages for Plaintiff TGB in the amount of $500,000.00, the exact amount to be determined by the jury at the time of trial;
7. If successful on the Tenth, Eleventh, or Twelfth Claims for Relief, non-economic damages for Plaintiff RB in the amount of $1,000,000.00, the exact amount to be determined the jury at the time of trial;
8. If successful on the Tenth, Eleventh, or Twelfth Claims for Relief, economic damages for Plaintiff RB in the amount of $750,000.00, the exact amount to be determined by the jury at the time of trial;
9. If successful on the Thirteenth, Fourteenth, or Fifteenth Claims for Relief, non-economic damages for Plaintiff MST in the amount of $1,000,000.00, the exact amount to be determined by the jury at the time of trial;
10. If successful on the Thirteenth, Fourteenth, or Fifteenth Claims for Relief, economic damages for Plaintiff MST in the amount of $750,000.00, the exact amount to be determined by the jury at the time of trial;
11. If successful on the Sixteenth, Seventeenth, or Eighteenth Claims for Relief, non-economic damages for Plaintiff TL in the amount of $1,000,000.00, the exact amount to be determined by the jury at the time of trial;
12. If successful on the Sixteenth, Seventeenth, or Eighteenth Claims for Relief, economic damages for Plaintiff TL in the amount of $500,000.00, the exact amount to be determined by the jury at the time of trial;
13. If successful on the Nineteenth, Twentieth, or Twenty-First Claims for Relief, non-economic damages for Plaintiff BPO in the amount of $1,000,000.00, the exact amount to be determined by the jury at the time of trial;
14. If successful on the Nineteenth, Twentieth, or Twenty-First Claims for Relief, economic damages for Plaintiff BPO in the amount of $500,000.00, the exact amount to be determined by the jury at the time of trial;
15. If successful on the Twenty-Second, Twenty-Third, or Twenty-Fourth Claims for Relief, non-economic damages for Plaintiff NCQ in the amount of $1,000,000.00, the exact amount to be determined by the jury at the time of trial;
16. If successful on the Twenty-Second, Twenty-Third, or Twenty-Fourth Claims for Relief, economic damages for Plaintiff NCQ in the amount of $500,000.00, the exact amount to be determined by the jury at the time of trial;
17. If successful on the Twenty-Fifth, Twenty-Sixth, or Twenty-Seventh Claims for Relief, non-economic damgages for Plaintiff WBL in the amount of $1,000,000.00, the exact amount to be determined by the jury at the time of trial;
18. If successful on the Twenty-Fifth, Twenty-Sixth, or Twenty-Seventh Claims for Relief, economic damgages for Plaintiff WBL in the amount of $500,000.00, the exact amount to be determined by the jury at the time of trial;
19. If successful on the Twenty-Eighth Claim for Relief, respective economic and non-economic damages for each of the Plaintiffs, as described above;
20. For Plaintiffs' costs and disbursements incurred; and
21. For any other relief this Court deems just and equitable.
Dated this
6th day of July, 2011.
O'DONNELL CLARK & CREW LLP < signature > Kelly Clark, OSB No. 831723
Kristian Roggendorf, OSB No. 013990
Stephen Crew, OSB No. 781715
Gilion C. Dumas, OSB No. 922932
Peter Janci, OSB No. 074249
O'DONNELL CLARK & CREW LLP
1650 NW Naito Parkway, Suite 302
Portland, OR 97209
503-306-0224 Office
503-306-0257 Fax
ksr@oandc.comgiliond@oandc.competerj@oandc.comOf Attorneys for Plaintiff[/list][/list][/list]
