david f. sugerman attorney, pc · defendant le cordon bleu north america, llc is a foreign...

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IN THE CIRCUIT COURT OF THE STATE OF OREGON

IN AND FOR THE COUNTY OF MULTNOMAH

Case No. 0803-03530 NATHAN SURRETT, individually and on behalf of all other similarly-situated individuals, and on behalf of herself only,

12 JENNIFER ADAMS fka JENNIFER SCHUSTER,

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PLAINTIFF'S SEVENTH AMENDED COMPLAINT AND DEMAND FOR JURY TRIAL

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15 vs.

Plaintiffs, CLASS ACTION- DAMAGES! EQUITABLE RELIEF

WESTERN CULINARY INSTITUTE, LTD; 16 LE CORDON BLEU NORTH AMERICA,

INC; and CAREER EDUCATION 17 CORPORATION,

(UNLAWFUL TRADE PRACTICES ACT (ORS 646.608, and FRAUD),

Claims Not Subject to Mandatory Arbitration

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Defendants.

Plaintiffs allege:

PRELIMINARY STATEMENT

1.

This is an action for money damages and equitable relief brought by Jennifer Adams

individually and by Nathan Surrett individually and on behalf of all similarly situated persons.

Plaintiffs allege claims for violation of the Unlawful Trade Practices Act, ORS 646.608, el seq.

Page I - PLAINTIFF'S SEVENTH AMENDED COMPLAINT AND DEMAND FOR JURY TRIAL

DAVID F. SUGERMAN ATTORNEY, PC 707 5\'1;1 Washington St., Suite 600 - Portland, Oregon 97205

(503) 228-6474

5/16/2017 1:25:10 PM080303530

1 and for fraud. To the extent allegations other than the certified allegations are alleged, Ms. Adams

2 alleges them solely on her own behalf.

3 Plaintiffs allege that defendants operated a trade school, Western Culinary Institute now

4 known as Le Cordon Bleu College of Culinary Arts in Portland ("WCI") and that defendants

5 induced plaintiffs and similarly-situated students to enroll at, attend, and incur financial

6 obligations, by making uniform misrepresentations common to plaintiffs and the class regarding

7 the value of the education, benefit of the degree, exclusivity of the degree, nature of ongoing

8 career placement, job placement rates, and by uniformly omitting to disclose to plaintiffs and the

9 class information about post-graduate salaries. Plaintiffs initially filed the case for equitable

10 relief, giving written notice of the intention to seek damages as required by ORCP 32H. More

11 than 30 days after giving notice, plaintiffs filed an amended complaint adding claims for

12 damages for themselves and the proposed class.

13 PARTIES

14 2.

15 Plaintiff Jennifer Adams attended WCI and paid tuition and incurred financial obligations

16 to do so as a result of misrepresentations and omissions made to plaintiff by defendants. Plaintiff

17 Adams attended WCI in 2006 and 2007, graduating in June, 2007. Plaintiff Nathan Surrett

18 enrolled and began attending WCI in May 2007 and graduated in September 2008. Plaintiff

19 Surrett paid tuition and incurred financial obligations as a result of misrepresentations and

20 omissions made to plaintiff and the class by defendants.

21 3.

22 Defendant Western Culinary Institute, Ltd. is a foreign corporation that operated Western

23 Culinary Institute, now known as Le Cordon Bleu College of Culinary Arts in Portland, an

24 Oregon trade school, located in Multnomah County. Defendant Western Culinary Institute, Ltd is

25 registered to do business in Oregon. Defendant-Western Culinary Institute, Ltd is a wholly-

26 - PLAINTIFF'S SEVENTH AMENDED COMPLAINT AND DEMAND FOR

JURY TRIAL

DAVID F. SUGERMAN ATTORNEY, PC 707 SW \'('ashington St., Suite 600 - Pordand, Oregon 97205

(503) 228·6~ 7 4

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owned subsidiary of defendant Career Education Corporation. After the commencement of this

action, defendant Western Culinary Institute, Ltd. merged into Le Cordon Bleu North America,

LLC. Defendant Le Cordon Bleu North America, LLC is a foreign corporation.

4.

Defendant Career Education Corporation (CEC) is a foreign corporation that provides

support and oversight to defendant Western Culinary Institute, Ltd. and Le Cordon BIeu North

America, LLC in its subsidiary'S operations ofWCI.

JURSIDICTION AND VENUE

5.

WCI operates in Multnomah County. Some of the acts complained of in this action took

place in Multnomah County.

CLASS ALLEGATIONS

6. The class consists of all current and former students who enrolled at Western Culinary Institue-

now known as Le Cordon Bleu College of Culinary Arts in Portland-on or after March 5, 2006

(up to and including March 1,2010), who attended Western Culinay Institute/Le Cordon Bleu

College of Culinary Arts in Portland on or after March 5, 2006 (up to including March I, 20 I 0)

and who made tuition payments or incurred financial obligations, excluding where applicable, all

officers and directors of defendants, attorneys for the class, any judge orjllror who sits on the

case, and any student who did not continue his or her studies due to academic ineligibility.

7.

Based on information and belief, plaintiff estimates that the class consists of

approximately 2,000 people. Regardless of the exact number, the class is so numerous that

joinder is impracticable because of the large size and geographic dispersion of the class.

- PLAINTIFF'S SEVENTH AMENDED COMPLAINT AND DEMAND FOR JURY TRIAL

DAVID F. SUGERMAN ATTORNEY, PC 707 SW Washington St., Suite 600 - Portland, Oregon 97205

(503) 228-6-174

1 8.

2 There are questions offact and law common to the class in that each class member has

3 suffered an injury as a result of defendants' conduct. Common questions oflaw and fact

4 predominate over any questions affecting only individual class members.

5 Common questions include:

6 A. Whether defendants violated the Unlawful Trade Practices Act by representing

7 that WCI had characteristics, benefits, or qualities that it did not have. ORS 646.608( I )(e);

8 B. Whether defendants violated the Unlawful Trade Practices Act, ORS

9 646.608(1 )(t) when, concurrent with delivery of services, defendants failed to disclose known

10 defects or material nonconformity;

11 C. Whether defendants violated the Unlawful Trade Practices Act by falsely

12 representing the nature of the transaction or obligation. ORS 646.608( I )(k);

13 D. Whether plaintiff and members of the class may state a claim for equitable relief

14 under the UTPA for violations ofORS 646.608;

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E.

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Whether defendants acted willfully as defined by ORS 646.638(1);

Whether, by making uni form misrepresentations and omissions to the class,

17 defendants violated the Oregon Administrative Rules, including:

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1. OAR 583-030-0035(8)(d);

2. OAR 583-030-0035(9);

3. OAR 583-030-0035(11 )(e);

4. OAR 583-030-0035( 12);

5. OAR 583-030-0035( 12)(a);

6. OAR 583-030-0035(20);

Whether the mandatory arbitration clause in the students' form contract is

25 unconscionable and unenforceable;


JURY TRIAL


(503) 228·6-174

1 H. Whether CEC can claim the benefits of the mandatory arbitration clause when

2 CEC was not a signatory of the contract;

3 I. Whether defendants made false representations regarding the value of the

4 education, benefit of the degree, exclusivity of the degree, nature of ongoing career placement,

5 and job placement rates to members of the class;

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Whether such representations were material;

Whether plaintiffs and members of the class had a right to rely on such statements

8 for their fraud claims;

9 L. Whether plaintiff and members ofthe class may prove reliance on a class-wide

10 basis;

11 M. Whether the defendants knew, but failed to provide to the plaintiffs and the class,

12 information about post-graduate salaries that should have been disclosed;

13 N. Whether defendants made representations and/or promises regarding the value of

14 the education, benefit of the degree, exclusivity of the degree, nature of ongoing career

15 placement, and job placement rates;

16 o. Whether defendants fraudulently concealed from plaintiffs and the class that they

17 made misrepresentations and omitted material facts.

18 9.

19 The claims of the named plaintiff are typical of the claims of the class in that:

20 A. The fraud and UTPA claims involve identical conduct in making uniform

21 representations and misrepresentations and omissions about the characteristics and value of the

22 WCI program;

23 8. Defendants operated WCI in a standardized manner with respect to

24 representations and omissions to prospective students, and defendants set policies for WCI and

25 oversaw its operations;


JURY TRIAL

DAVID F. SUGERMAN ATTORNEY, PC 707 S\'\' Washington St., Suite 600 - Portland, Oregon 97205

(503) 228·6474

1 C. The injuries suffered by the named plaintiff and the class members differ only in

2 the amount of damage; and

3 D. The named plaintiff's claims for relief are based upon the same legal theories as

4 are the claims of the class members.

5 10.

6 The named plaintiff will fairly and adequately protect and represent the interests of the

7 class in that:

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S.

His claims are typical of the claims of the class members;

He is represented by attorneys who are qualified and competent counsel who will

10 vigorously prosecute this litigation; and

11 C. His interests are not antagonistic to or in conflict with the interests of the class

12 members.

13 II.

14 A class action is superior to other available methods for the fair and efficient adjudication

15 of this case in that:

16 A. Common questions oflaw and fact predominate over factors affecting only

17 individual members;

18 B. As far as plaintiff knows, no class action that purports to include WCI students

19 has been commenced;

20 C. Individual class members have little interest in controlling the litigation due to the

21 high cost of each individual action, the risk of fees and costs, and because plaintiff and his

22 attorneys will vigorously pursue the claims;

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D. The forum is desirable as defendants do business here;


DAVID F. SUGERMAN ATTORNEY, PC 707 SW Washington St., Suite 600 - Pordand, Oregon 97205

(503) 228·6-174

1 E. A class action will be an efficient method of adjudicating the claims of the class

2 members who have suffered monetary damages as a result of the same type of conduct by

3 defendants; and

4 F. In the aggregate, class members have claims for relief that are significant in scope

5 relative to the expense of the litigation.

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7 More than 30 days before seeking damages, plaintiff complied with the requirements of

8 ORCP 32H by delivering notice and demand on defendants in writing by service on their

9 registered agent and by certi tied or registered mail, return receipt requested.

10 ALLEGATIONS OF FACT

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12 Defendants' WCI purports to provide trade school education to plaintiffs and class

13 members that will prepare them for careers in the food service and hospitality industries.

14 14.

15 Defendants made uniform misleading representations and omissions common to

16 plaintiffs and the class regarding the value of the WCI education, benefit of the degree,

17 exclusivity of the degree, nature of ongoing career placement, job placement rates, post-graduate

18 salaries, and its operation under the regulations of Oregon's Office of Degree Authorization, in

19 violation of the Oregon Unlawful Trade Practices Act, including:

20 A. Offering student admission without receipt of evidence that the applying student

21 could reasonably expect to benefit from the education obtained in violation of duties under OAR

22 583-030-0035(9) and in violation of OAR 583-030-0035(12); OAR 583-030-oo35(12)(a); OAR

23 583-030-0035(20) and ORS 646.608(1)(e), \ (k), and (I)(t);

24 B. Affirmatively representing in the WCI catalog that the Le Cordon Bleu curriculua

25 gives students greater opportunities to acquire the knowledge and skills necessary to excel in the


JURY TRIAL


(503) ?'8·6474

1 cUlinary/hospitality world, when in fact Le Cordon Bleu training does not provide those benefits

2 in violation of OAR 583-030-0035(12); OAR 583-030-0035(12)(a); OAR 583-030-0035(20) and

3 ORS 646.608(1)(e), I (k), and (I)(t);

4 C. Affirmatively representing in the WCI school catalog that the school trains

5 students for entry level jobs, but failing to disclose that those entry level jobs do not require that

6 training in violation of OAR 583-030-0035(12); OAR 583-030-0035(12)(a); OAR 583-030-

7 0035(20) and ORS 646.608(1)(e), I(k), and (I)(t);

8 D. Affirmatively representing in the WCI catalog that the school trains students for

9 entry level positions but failing to disclose that their training would not improve students'

10 qualifications for entry level positions in violation of OAR 583-030-0035(12); OAR 583-030-

11 0035(12)(a); OAR 583-030-0035(20) and ORS 646.608(1 )(e), 1 (k), and (I )(t);

12 E. Knowing, but failing to disclose, that WCI training would qualify graduates for

13 mostly low paying, poverty-wage jobs in violation of OAR 583-030-0035( 12); OAR 583-030-

14 0035(12)(a); OAR 583-030-0035(20) and ORS 646.608(1)(e), I(k), and (I)(t);

15 F. Knowing, but failing to disclose, that WCI students will incur debts that cannot be

16 repaid with low paying jobs for which their education qualifies them in violation of OAR 583-

17 030-0035(12); OAR 583-030-0035(12)(a); OAR 583-030-0035(20) and ORS 646.608(1)(e),

18 1 (k), and (I )(t);

19 G. Knowing, but failing to disclose, that most WCI graduates will not eam enough to

20 allow them to pay off school loans in violation of OAR 583-030-0035(12); OAR 583-030-

21 0035(12)(a); OAR 583-030-0035(20) and ORS 646.608(1)(e), 1 (k), and (I)(t);

22 H. Knowing, but failing to disclose, that defendants were so concemed about loan

23 defaults given the imbalance between WCI tuition and expected wages that CEC paid to Sallie

24 Mae 25 percent or more of sub-prime loans that Sallie Mae made to WCI students in violation of

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JURY TRIAL


(503) 228·6474

1 OAR 583-030-0035(12); OAR 583-030-0035(12)(a); OAR 583-030-0035(20) and ORS

2 646.608(1)(e), I (k), and (I)(t);

3 1. Knowing, but failing to disclose, that students who attend WCI would not obtain

4 material benefit from the course of study in violation of OAR 583-030-oo35(8)(f), OAR 583-

5 030-0035(9), OAR 583-030-0035(12); OAR 583-030-oo35(12)(a); OAR 583-030-0035(20) and

6 ORS 646.608(1)(e), I (k), and (I)(t);

7 J. Calculating job placement rates in a manner inconsistent with that required by the

8 State of Oregon's governing regulations in violation of the standards set forth in OAR 583-030-

9 0035(8)(d);OAR 583-030-0035(12); OAR 583-030-0035(12)(a); OAR 583-030-0035(20) and

10 ORS 646.608(1)(e), I (k), and (I)(t);

Jl K. As part of the enrollment process, providing each student with graduate job

12 placement rates that affirmatively represented that it places over 90 percent of its students in

13 jobs, but failing to disclose that their placement rate calculations violated Oregon regulations and

14 the placement those rates were composed mostly of jobs that do not require culinary training like

15 prep cook and line cook in violation of OAR 583-030-0035(8)(d); OAR 583-030-0035(12); OAR

16 583-030-0035(12)(a); OAR 583-030-0035(20) and ORS 646.608(1)(e), I (k), and (I)(t);

17 L. Defendants failed to disclose that their representations about the value of the

18 education, benefit of the degree, exclusivity of the degree, nature of ongoing career placement,

19 and job placement rates, were false and misleading in violation of OAR 583-030-0035(12); OAR

20 583-030-0035(12)(a); OAR 583-030-0035(20) and ORS 646.608(1)(e), I(k), and (I)(t);

21 M. Defendants affirmatively represented that they provide post-graduation career

22 placement assistance, but by inflating job placement figures to include jobs for which a culinary

23 degree is unnecessary, they misrepresented the nature of career services that they would provide

24 in violation of OAR 583-030-0035(11)( e); OAR 583-030-0035( 12); OAR 583-030-0035( 12)(a);

25 OAR 583-030-0035(20) and ORS 646.608(1)(e), I (k), and (\)(t);


JURY TRIAL

DAVID F. SUGERMAN ATTORNEY, PC 707 S\\I Washington St., Suite 600 - Pordand, Oregon 97205

(503) 228·6474

1 N. Defendants affirmatively represented that they provide post-graduation career

2 placement assistance, but failed to disclose that this assistance focused largely on compiling

3 posted job openings from publicly available sources like Craig's List and local help wanted ads

4 that were accessible to anyone, whether enrolled at the school or not in violation of OAR 583-

5 030-0035(11)(e); OAR 583-030-0035(12); OAR 583-030-0035(12)(a); OAR 583-030-0035(20)

6 and ORS 646.608(1)(e), I (k), and (I)(t);

7 O. Defendants affirmatively represented that they would provide ongoing career

8 placement services to graduates in violation of duties created by OAR 583-030-0035(11)(e);

9 OAR 583-030-0035(12); OAR 583-030-0035(12)(a); OAR 583-030-0035(20) and ORS

10 646.608(1)(e), I (k), and (I)(t).

11 FRAUDULENT CONCEALMENT

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13 Defendants are estopped from relying on a statute of limitations defense because they

14 intentionally lulled plaintiffs and the class, by affirmative inducement and wrongful, active

15 concealment of material facts, into delaying the filing of a cause of action. Defendants had

16 continuing common law and regulatory duties to correct the alleged misrepresentations and

17 omissions and disclose the true character, quality, and nature of their programs, but they

18 intentionally failed to do so. As a result, neither plaintiffs nor any class member could have

19 discovered all elements of the alleged torts until, at the earliest, seeking employment after

20 completing their education at WCI.

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22 Defendants made the representations and failed to make disclosures knowingly and

23 intentionally in an effort to induce prospective students to enroll at, attend, and incur financial

24 obligations to pay WCI and in order to retain the tuition money of plaintiff and the class.

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JURY TRIAL


(503) 228·6·m

1 PLAINTIFF'S FIRST CLAIM FOR RELIEF

2 UNLAWFUL TRADE PRACTICES ACT

3 FIRST COUNT-REFUND DAMAGES

4 17.

5 Defendants willfully violated ORS 646.608(1)(e), I(k), and I (t), and as a result of their

6 misrepresentations and failures to disclose, plaintiffs and members of the class suffered

7 ascertainable losses of money.

8 18.

9 Plaintiffs seek certification of an issue class to address common issues of fact and law set

10 forth in ~~8A-F; 81-J; 8M-O; 14A-O; 15; and 16.

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12 Plaintiffs and members of the class are entitled to full refunds, together with prejudgment

13 interest and repayment of sufficient funds to satisfY the debts they incurred to attend WeI in

14 amounts to be proved at trial. ORS 646.636; ORS 646.638

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16 Plaintiffs and members of the class are entitled to recover damages in the form of student

17 loan principal and/or tuition payments made, plus interest. In addition, plaintiffs and members of

18 the class are entitled to recover relocations expenses and lost wages incurred during their periods

19 of attendance at school in amounts to be proven at trial. Plaintiffs and the class are entitled to

20 recover attomeys' fees and costs. ORS 646.638(3).

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22 Plaintiffs and members of the class are entitled to an order certifying an issue class for

23 refunds and economic damages, with subsequent adjudications of indivjdual questions of

24 causation, and damages. Plaintiffs and members of the class are also entitled to equitable relief,

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26 Page II - PLAINTIFF'S SEVENTH AMENDED COMPLAINT AND DEMAND FOR

JURY TRIAL


(503) 228-6474

1 including an accounting and production of papers and information sufficient to calculate actual

2 sums of money due to them.

3 22.

4 Defendants acted for their own financial benefit and with malice or have shown a

5 reckless and outrageous indifference to a highly unreasonable risk of harm and have acted with a

6 conscious indifference to the welfare of others. As a result, plaintiffs and the class are entitled to

7 recover punitive damages in an amount not to exceed $50 million.

8 SECOND COUNT-DIMINISHED VALUE

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10 Plaintiff re-incorporates Til 1-17; 20-22.

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12 The education and training sold by defendants were worth less than the price charged on

13 account of the previously-alleged violations.

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15 Defendants charged plaintiffs and the class varying amounts, but in no case more than

16 $47,000 per plaintiff and class member for these educational programs. Due to the previously-

17 described characteristics, the educational programs had an actual value of no more than $9, I 00.

18 Plaintiffs and members of the class are entitled to recover diminished value damages in amounts

19 to be proved at trial, and which will not exceed $61 million, plus interest. Plaintiffs and

20 members of the class are also entitled to equitable relief, including an accounting and production

21 of papers and information sufficient to calculate actual sums of money due to them.

22 SECOND CLAIM FOR RELIEF FRAUD

n 26.

24 Plaintiff re-incorporates 'IMI1-16; 18-22; and 25.

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JURY TRIAL


(503) 228-6-174

1 27.

2 Defendants' representations were false and material, and their omissions were material,

3 to plaintiffs' and class members' decision to enroll, attend, and incur financial obligations to

4 WCI and others. Defendants made the representations with knowledge of their falsity. Plaintiffs

5 and members of the class had a right to rely on the defendants' misrepresentations and

6 statements and actually relied upon them.

7 U.

8 As a result, plaintiffs and members of the class suffered economic damages in the form of

9 student loan principal and/or tuition payments made, plus prejudgment interest, all to their

10 economic damages in amounts to be proved at trial. Plaintiffs and members of the class are

11 entitled to recover economic damages in amounts to be proved at trial

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13 In addition, plaintiffs and class members are entitled to recover lost wages incurred while

14 attcnding school and moving cxpenses incurred to attend school, in amounts to be proved at trial.

15 WHEREFORE, plaintiffs and the class seek relief from defendants, and each of them, as follows:

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a. On their UTPA Claim:

Count I: Plaintiffs and members of the class are entitled to an order certifying

this matter as an issue class, with a class trial on common questions of fact

and law and class member trials on causation and damages consisting of full

refunds, together with prejudgment-interest and repayment of sufficient funds

to satisry the debts they incurred to attend WCI; relocation expenses and lost

wages incurred during attendance; class-wide punitive damages in amount not

to exceed $50 million; equitable relief, including an accounting and

production of papers and information sufficient to calculate actual sums of

money due to them; and attorneys' fees and costs.

Page \3 - PLAINTIFF'S SEVENTH AMENDED COMPLAINT AND DEMAND FOR JURY TRIAL


(503) 228-.6474

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b.

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Count 2: Plaintiffs and class members are entitled to recover diminished value

damages in amounts not to exceed $61 million, plus prejudgment interest

equitable relief, including an accounting and production of papers and

information sufficient to calculate actual sums of money due to them;

attorneys fees and costs; and class-wide punitive damages in amount not to

exceed $50 million

On their fraud Claim:

Plaintiffs and members of the class are entitled to an order certifying this

matter as an issue class, with a class trial on common questions of fact and law

and class member trials on reliance and damages and damages consisting of full

refunds, together with prejudgment interest, and repayment of sufficient funds to

satisfy the debts they incurred to attend WCI, plus prejUdgment interest, and

class-wide punitive damages in amount not to exceed $50 million. Plaintiffs are

also entitled to recover moving expenses and lost wages; and

Such other relief as the court may deem just.

DATED this 16th day of May, 2017.

By: rD~a~v~I ~.~u~g=e=rm~n~,~~~~~no-DA VID F. SUGERI\tAN 520 S.W. Sixth Av St . 920 Portland, Oregon 972 Phone: (503) 228-6474 Fax: (503) 224-2764 E-Mail: [email protected]

Amy Johnson, OBS No. 112044 5836 SE Madison St. Portland, OR 97215 Phone: 503-939-2996 E-mail: [email protected]


DAVID F. SUGERMAN ATTORNEY, PC 707 SW Washington St., Suite 600 - Portland, O regon 97205

(503) 228-6-174

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Tim Alan Quenelle, OSB No. 93400 TIM QUENELLE, PC 4 I 5 North State Street, Suite 132 Lake Oswego, OR 97034 Telephone (503) 675-4330 Email: [email protected].

Attorneys for Plaintiffs and the class



(503) 228-6~7~

1 PLAINTIFFS DEMAND A JURY TRIAL.

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3 DATED this 161h day of May, 2017.

4 Respectfully submitted,

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By: r;D:-av:l.\;;;;>";'F!"'. 'fruAg~e--rm:-!.an-, --rbS;;=B~:-.""8;r6"'2 9"'8' DAVID F. SUGERM TIORNEY PC 520 S.W. Sixth Ave., Ste. 920 Portland, Oregon 97204 Phone: (503)228-6474 Fax: (503) 224-2764 E-Mail: [email protected]

Of Attorneys for Plaintiff and the class

Tim Alan Quenelle, OS8 No. 93400 TIM QUENELLE, PC 415 North State Street, Suite 132 Lake Oswego, OR 97034 Telephone (503) 675-4330 Email: [email protected].

Attorney for Plaintiff Adams



(503) 228-6-l74

1 CERTIFICATE OF SERVICE

2 I hereby certify that I served the foregoing PLAINTIFF'S SEVENTH AMENDED

3 COMPLAINT AND DEMAND FOR JURY TRIAL on the following person(s) on this same

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day:

Il9 by electronic mail and notice of filing using the CmlECF system

Stephen English Thomas R Johnson Heidee Stoller Perkins Coie 1120 NW Couch Street, Tenth Floor Portland OR 97209-4128 [email protected] [email protected] [email protected]

DATED this 161h day of May, 2017.

BY:=~~~d~ ~:::....,.=,.... David F. ugerma No. 86298 DA VID F. SUGER A TIORNEY, PC 520 S.W. Sixth Ave. S .9 0 Portland, Oregon 972 Phone: (503) 228-6474 Fax: (503) 224-2764 E-Mail: [email protected] Attorneys for Plaintiff

Page 1 - CERTIFICATE OF SERVICE


(503) 228-CH74

david f. sugerman attorney, pc · defendant le cordon bleu north america, llc is a foreign...

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