Qadira Stephens v. Multnomah County OHSU Providence For Malpractice, Child Abuse, Burn, Hate Crime

Page 1 COMPLAINT FOR DEPRIVATION OF RIGHTS, CONSPIRACY TO INTERFERE
WITH CIVIL RIGHTS, NEGLECT TO PREVENT, ETC.

Karellen and Renee Stephens
7135 SW 54
th
Avenue
Portland, OR 97219
503-977-7935
karellen.stephens@comcast.net
renee.stephens1@comcast.net

Plaintiffs in Pro Se

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF OREGON
PORTLAND DIVISION

KARELLEN STEPHENS, RENEE
STEPHENS, and QADIRA STEPHENS by
and through her guardian ad litem
KARELLEN STEPHENS,

Plaintiffs,
v.
MULTNOMAH COUNTY, by an through its
Judicial Department; Judge DAVID F.
REES, in his individual capacity; Judge
ADRIENNE NELSON, in her individual
capacity; Presiding Judge JEAN K.
MAURER, in her individual capacity;
JAMES M. CALLAHAN, in his individual
capacity; CALLAHAN AND SHEARS, PC;
SCOTT KOCHER, in his individual
capacity; RICHARD VANGELISTI, in his
individual capacity; and VANGELISTI
KOCHER, LLP; WASHINGTON
COUNTY; NIKE, INC.; PHIL KNIGHT;
STOEL RIVES, LLP; AMY JOSEPH
Case No. 3:12-CV-00171-MO
PLAINTIFF STEPHENS SECOND
AMENDED COMPLAINT FOR
DEPRIVATION OF RIGHTS (42 U.S.C.
1983); CONSPIRACY TO INTERFERE WITH
CIVIL RIGHTS (42 U.S.C. 1985(3)); FOR
NEGLECT TO PREVENT (42 U.S.C. 1986);
INTENTIONAL INFLICTION OF SEVERE
EMOTIONAL DISTRESS; RACE
DISCRIMINATION (42 U.S.C. 1981(a));
ECONOMIC DISCRIMINATION;
OBSTRUCTIONS OF JUSTICE;
CONSPIRACY TO OBSTRUCT JUSTICE;
CONSPIRACY TO COVER UP CHILD
ABUSE AND NEGLECT; CHILD ABUSE;
CHILD NEGLECT; WILLFUL
MISCONDUCT; ATTEMPTED MURDER;
HATE CRIME; FAILURE TO INVESTIGATE;
FAILURE TO TREAT; CONSPIRACY TO
COMMITT RACKATEERING;
RACKATEERING; CONSPIRACY TO
COMMIT MURDER; RECKLESS

PEDERSON; P.K. RUNKLES-PEARSON;
TODD BURKHOLDER; AIMEE
MCQUISTON; REX BURKHOLDER;
PROVIDENCE ST. VINCIENT
HOSPITAL; PROVIDENCE HEALTH
SERVICES; OREGON HEALTH AND
SCIENCES UNIVERSITY HOSPITAL; DR.
JOSEPH E. ROBERTSON, OREGON
EMERGENCY PHYSICIANS; JR.; DR.
JULIE ANDREWS; DR. SARA
TUBBESING; NANCY GORDON-
ZWERLING; DR. DAVID R. SOLODNZ;
STATE FARM FIRE AND CASUALTY
COMPANY; BETH PHIPPS; SUSAN
OLEARY; PORTLAND PUBLIC
SCHOOLS; RUDY R. LACHENMEIER;
LACHENMEIER ENLOE RALL AND
HEINSON; BETSY FERNLY; JUDGE
DALE R. KOCH; JUDGE MICHAEL
MCSHANE; JOHN BARKER; SUSAN
GLOSSER; CITY OF PORTLAND;
PORTLAND POLICE BUEARU; MAYOR
SAM ADAMS; CHIEF OF POLICE ROSIE
SIZER; CHIEF OF POLICE MICHAEL
REESE; OFFICER SGT. DAN LIU;
OFFICER MULBERRY; OFFICER
HERBERT MILLER; OFFICER JOHN
ECKHART; OFFICER BRET SMITH;
CHARLIE G. JENKINS; FIRDOUSI
CHOWDHURY; KEELY WEST; JACOB
WEIGLER; EQUAL EMPLOYMENT
OPPORTUNITIES COMMISION;
FEDERAL BUEARU OF
INVESTIGATION; AGENT GLENN G.
NORLING; OREGON STATE BAR;
SCOTT A. MORRILL; SYLVIA E.
STEVENS; JUDGE DONALD R.
LETOURNEAU; ANDY SIMRIN; JUDGE
SCHUMAN; JUDGE WOLLHEIM; JUDGE
ROSENBLUM; JUDGE HASELTON;
ENDANGERMENT; PUBLIC CORRUPTION;
LIBEL, SLANDER, AND DEFAMATION

JURY TRIAL DEMANDED

JUDGE ARMSTRONG; JUDGE DUNCAN;
CHIEF JUDGE PAUL J. DE MUNIZ;
OREGON MEDICAL BOARD; MITRA
SHARI; OREGON DEPARTMENT OF
JUSTICE; OREGON DEPARTMENT OF
HUMAN SERVICES; JOHN KROGER;
DWIGHT C HOLTEN; MULTNOMAH
COUNTY DISTRICT ATTORNEY;
CARES NORTHWEST; AND MANY
OTHER UNKNOWN AND UNAMED
INDIVIDUALS.

Defendants.
I. JURISDICTION
1. This action is brought for violations of the plaintiffs I, VII, XIII, and XIV Amendments U.S.
Constitutional rights; conspiracy to interfere with the plaintiffs civil rights pursuant to 42
U.S.C. 1985; for neglect to prevent pursuant to 42 U.S.C. 1986; for the deprivation of the
plaintiffs rights pursuant to 42 U.S.C. 1983; and for race discrimination pursuant to 42
U.S.C. 1981. This Court has original jurisdiction for violations of the United States
Constitution and U.S. laws under 28 U.S.C. 1331.
II. PARTIES
2. Plaintiffs Renee Stephens, Karellen Stephens and Qadira Stephens are natural born citizens
of the United States of America and residents of the State of Oregon in Multnomah County.
Qadira Stephens is a 13 year old girl and Renee Stephens is the natural father of Qadira
Stephens and Karellen Stephens is the natural mother of Qadira Stephens and her duly
appointed guardian ad litem. Karellen and Renee Stephens met at Jefferson High school and
began dating in 1995, and subsequently married in 1998 and had four children, Qadira,
Kymani, Alma Kamaya, and Qayden. Renee began working at Adidas America through a

joint venture with SEI when he was 15 years of age, and went on to have a successful career
at Nike until the year 2007 when he was terminated after complaining about workplace
harassment by a senior coworker. Renee was blacklisted after he complained and is now
unemployed after being forced to quit his security job fearing for his own physical safety.
Karellen Stephens is a native Oregonian who works as a caregiver for the elderly at
Benchview Place Elderly Care Home which is run by her mother Audrey Lloyd. Qadira
Stephens is the oldest daughter of Karellen and Renee Stephens. She is a wonderful little girl
who is good at school, loves Japan, loves her brothers and her sister and has kept an amazing
attitude despite all that has happened to her. Everyone who knows Qadira can attest to her
upstanding character and poise. Kymani Stephens is 11 years old and a wonderful artist.
Kymani likes to play Mindcraft and spend time with his brother and sisters. Alma Kamaya is
8 years old and is Qadiras best friend. Alma Kamaya likes to bake and watch Japanese
movies with her sister. Qayden is 7 years old and likes action movies, Legos, cars, and
hanging out with his brothers and sisters. The Stephens children have been a wonderful
support system for their parents and have sought to bring them many hours of joy throughout
this entire ordeal.
3. This court is well aware of whom the Defendants are in this case and they need no
introduction.
III. INTRODUCTION
4. For the purposes of this complaint, Defendants refer to all named defendants in this case
unless so specifically stated. Defendant OHSU refers to all OHSU defendants. Defendant
DHS refers to all DHS Defendants. Defendant Nike refers to all Nike Defendants.
Defendant Judges refers to all defendant judges. Defendant Vangelisit Kocher refers to the

law firm of Vangelisti Kocher and Scott Kocher and Richard Vangelisti. Defendant Callahan
refers to James Callahan and Callahan and Shears PC. Defendant Stoel Rives refers the law
firm of Stoel Rives, P.K Runkles Pearson and Amy Joseph Pederson. Defendant Portland
Public Police Bureau refers to all Defendant Police officers, and the City of Portland
Defendants. Defendant State Farm Fire and Casualty Company refers to all State Farm
defendants, including Beth Phipps and Susan OLeary. Defendant Lachenmier refers to
Rudy Lachenmier, Besty Fernly and law firm of Lachenmier Enloe and Heinson. Defendant
Oregon State Bar refers to all Oregon State bar defendants.
IV. SHORT CONCISE STATEMENT OF FACTS
5. This action arises out of a malicious rumor that was started by Defendant Todd Burkholder
and Defendant Rex Burkholder after Plaintiff Q Stephens was burned in a suspicious manner
at the home of Defendant Todd Burkholder and Defendant McQuiston on the night of April
12
th
2007 when she was eight years old. Plaintiff Q Stephens was taken to Defendant
Providence Hospital for treatment and seen by Defendant Julie Andrews who failed to do her
job and appropriately treat Plaintiff Q Stephens injury by having her immediately transferred
to the Oregon Burn Unit for an appropriate medical evaluation, and reporting plaintiff Q
Stephens injury to the proper authorities. Defendant Andrews instead gave Plaintiff Q
Stephens drugs for pain, wrapped her wound and sent her home within the hour to be cared
for by Plaintiff K and R Stephens. Plaintiff K and R Stephens were traumatized by the event
and did not know what to do which is why they had taken Plaintiff Q Stephens to Defendant
Providence hospital in the first place. Plaintiff K and R Stephens were faced with providing
care for Plaintiff Q Stephens and Plaintiff R Stephens called Defendant
McQuiston/Burkholder early the next morning to get their homeowners insurance because

Plaintiff Q Stephens burns were bad and Plaintiff K Stephens needed to take Plaintiff Q
Stephens to OHSU that day for further evaluation and a bandage change as Julie Andrews
had directed them to do. Plaintiff K Stephens took Plaintiff Q Stephens to OHSU and were
seen by Defendant Tubbesing at OHSU who also did not do her job to protect Defendants
McQuiston and Burkholder. Tubbesing did not treat Plaintiff Q Stephens or report her injury
to anyone. Tubbesing looked at Plaintiff Q Stephens leg and then wrapped her leg back up
and told Plaintiff K Stephens to take Plaintiff Q Stephens home and administer three times
daily wound care. Defendant Tubbesing directed Plaintiff K Stephens and Plaintiff R
Stephens to go to the medical store and buy bandages, crutches, and Silvadene and to take
care of Plaintiff Q Stephens burn at their home without any medical supervision. Plaintiff K
Stephens called OHSU 2 days later afraid that she was doing something wrong and was told
again by Defendant Solondz that she was doing everything just fine and not to bring Plaintiff
Q Stephens back to the hospital. Plaintiff K and R Stephens believed Defendant OHSU and
continued to do as they were told.
6. Defendant Todd Burkholder was upset that Plaintiff K and R Stephens took Plaintiff Q
Stephens to the doctor because Defendant Todd Burkholder felt from his own untrained
assessment of the burn that the burn was more like a sunburn and did not really need any
medical attention. Defendant Todd Burkholder had insisted to Plaintiff K and R Stephens
that they should have just put Aloe Vera on Plaintiff Q Stephens burn instead of take her to
the hospital. Defendant Burkholder and Defendant McQuiston decided that Plaintiff K and R
Stephens were just blowing the whole injury out of proportion in order to get money from
their insurance company and Defendant Providence and Defendant OHSU did nothing to
disabuse them of that notion when they failed to treat Plaintiff Q Stephens or elevate her

injury to the proper authorities and medical experts.. Defendant Todd Burkholder repeated
the assertion that Plaintiff K and R Stephens were money hungry to Defendant Rex
Burkholder, Defendant State Farm, Defendant Portland Public Schools and anyone else who
would listen to deflect from the real issue which was what Defendant Todd Burkholder and
Defendant McQuiston had been doing on the night of April 12
th
2007 with Plaintiff Q
Stephens and Sophie Burkholder.
7. Plaintiff Q Stephens and Sophie Burkholder has been playing an adult supervised naked
game at the Defendants house in there bathroom when Defendant Todd Burkholder heated up
a kettle of scalding hot water and gave it to Defendant McQuiston. Defendant McQuiston
took the kettle into the bathroom and burned Plaintiff Q Stephens on her leg. Defendant
McQuiston and Defendant Todd Burkholder did not seek medical care for Plaintiff Q
Stephens opting instead to wrap her in a towel and put her down into their basement until
Plaintiff K Stephens called to say goodnight to Qadira and they had to admit that she was
burned.
8. Defendant Rex Burkholder who is a prominent politician in Oregon and personally knows
Joe Robertson who is the President of OHSU hospital repeated Defendant Todd Burkholders
assertions about the Stephens being money hungry to Defendant Joe Robertson. Defendant
Rex Burkholder asked Defendant Robertson to downplay the injury since it was just an
accident. Defendant OHSU did nothing to treat Plaintiff Q Stephens because despite the
fact that her burns looked really bad and despite their own diagnosis which called for
Plaintiff Q Stephenss immediate transfer to the Oregon Burn center Defendant Joe
Robertson did not want to be responsible for the criminal prosecution of Defendant Todd
Burkholder and Defendant McQuiston especially because now Defendant Robertson had it

on good authority from Defendant Rex Burkholder that Plaintiff K and R Stephens just
wanted some money.
9. Defendant Todd Burkholder and Defendant McQuiston assured all involved parties that
what they were doing was innocent and didnt need to be investigated because of who they
were, and who they were related to. They used the Odyssey Program at Hayhurst
Elementary School with the consent of Defendant Portland Public Schools to help explain
away the naked game they had been playing with the two little girls and because Plaintiff Q
Stephens is not white, wealthy, or related to anyone of importance and since Defendant Joe
Robertson had it on good authority from Todd Burkholder and Rex Burkholder that Plaintiff
K and R Stephens were just money hungry they all agreed to just sweep this little matter
under the rug. Defendant OHSU did not seek an outside expert opinion of Plaintiff Q
Stephens injury because they were concerned that not everyone would understand their
position because of the taboo nature of the circumstances of how the burn injury had
occurred. Defendant Rex Burkholder and Defendant Robertson were worried that the
doctors at the Oregon burn unit would have to admit Plaintiff Q Stephens because her
diagnosis called for her to be admitted and if she was admitted to the burn unit or any
hospiatl it would be impossible to hide what Defendant Todd Burkholder and Defendant
McQuiston had done to Plaintiff Q Stephens.
10. Defendant Nike became involved because they were ill equipped when Plaintiff R Stephens
complained about workplace harassment in early March 2007. Because of the taboo subject
matter of Plaintiff R Stephens complaint Defendant Nike did a shallow investigation and
tried to sweep the whole matter under the rug as quickly as possible. Defendant Nike was
upset when Plaintiff R Stephens filed an EEOC charge against them because they did not

want anyone to know about Plaintiff R Stephens complaint because not only had Defendant
Nike admitted on paper that something had happened Defendant Nike was embarrassed about
the subject matter of Plaintiff R Stephens complaint. Defendant Nike was unconcerned for
the health and welfare of Plaintiff R Stephens because Plaintiff R Stephens is not white,
wealthy, or related to anyone of importance. Defendant Nike took Randy Wolfe on his word
that his actions amounted to a bunch of crude jokes and that Plaintiff R Stephens was just
blowing the whole thing out of proportion. Defendant Nike heard the rumor being passed
around by Defendant Rex Burkholder, Defendant Providence, Defendant OHSU, and
Defendant State Farm and believed that Plaintiff R Stephens was just money hungry and
attempting to exploit his daughter and Defendant Nike because Plaintiff R Stephens is not
white, wealthy, or related to anyone of importance. Defendant Nike started a campaign to
punish Plaintiff R Stephens by refusing to address any of Plaintiff R Stephens concerns and
refusing to move Plaintiff R Stephens. Defendant Nike informed all of Plaintiff R Stephens
co-workers and anyone that would listen that Plaintiff R Stephens was money hungry and
attempting to exploit his daughter and Nike. Defendant Nike did not need any evidence to
support its belief because Defendant Rex Burkholder is a prominent Oregon politician and
when he speaks people listen. Defendant Providence and Defendant OHSU are prominent
hospitals and Defendant State Farm is a reputable insurance company and Plaintiff R
Stephens is nobody. In the summer of 2007 Defendant EEOC asked Plaintiff R Stephens to
drop his initial charge. Plaintiff R Stephens declined to drop his charge because it had not
been investigated and he was still hoping to be moved away from Randy Wolfe. Plaintiff R
Stephens was traumatized from Randy Wolfes actions, the death of his father, and his
daughter being burned. Plaintiff R Stephens would have welcomed a move away from

Randy and all of the individuals involved in his complaint against Randy Wolfe. Defendant
Nike interpreted Plaintiff R Stephens refusal as further evidence that he was money hungry
and decided to punish plaintiff R Stephens by firing him right before the start of the school
year. Plaintiff R Stephens filed a charge of retaliation after he was fired and Defendant Nike
was furious and told federal investigator Matthew Cleman to drop all the charges because
Plaintiff R Stephens did not deserve anything because he was money hungry and
attempting to exploit his daughter and Nike. Defendant Cleman needed more than baseless
accusations to absolve Defendant Nike of all the charges because based on the evidence
submitted Defendant Nike was guilty and should be reprimanded. Defendant Nike asked
Defendant Vangelisti Kocher to file the lawsuit against McQuiston to manufacture tangible
evidence to prove to EEOC investigator Matthew Cleman that Plaintiff K and R Stephens
were money hungry and attempting to exploit their daughter and Nike.
11. On January 22 2008 Defendant OHSU, Defendant Rex Burkholder, and Defendant
Providence became aware that Plaintiff Q Stephens was suffering from a life threatening
infection because Plaintiff K Stephens had brought her in to be evaluated for a possible case
of Kawasakis syndrome. Defendant OHSU did not inform Plaintiff K and R Stephens that
Plaintiff Q Stephens was suffering from severe internal distress because since they had done
nothing to treat her burn injury and committed a crime by doing so Defendant OHSU started
spreading the rumor that Plaintiff K and R Stephens had done something to harm their
daughter. Defendant OHSU and Defendant Providence could not accept that they had done
something to further harm Plaintiff Q Stephens when they failed to treat her burn and decided
it was plaintiff K and R Stephens that must have done something to harm Plaintiff Q
Stephens when they had cared for her burn injury. Defendant OHSU and Defendant

Providence wanted to distract all involved parties from what they had done in the event that
Plaintiff Q Stephens suddenly passed away from her internal distress. Defendant Nike now
informed Defendant EEOC that Plaintiff R Stephens and Plaintiff K Stephens were horrible
people who had harmed their daughter in an effort to get money. Defendant Cleman
believed this rumor and to punish Plaintiff K and R Stephens he issued three indeterminate
findings against Plaintiff R Stephens on January 30
th
2008. Plaintiff K and R Stephens did
their best to deal with each oncoming situation, they dealt with the loss of Plaintiff R
Stephens father, Plaintiff Q Stephens burn injury and Alma Kamayas pneumonia, and the
loss of Plaintiff R Stephens job and again Alma Kamayas Kawasakis syndrome which is a
rare life threatening autoimmune disorder of which she was diagnosed and treated for in
October of 2007. Plaintiff R Stephens relinquished his retirement to save the life of Alma
Stephens as the family waited for help from the EEOC. When the EEOC issued its three
indeterminate findings Plaintiff R Stephens diligently continued to seek work in his industry
and counsel within and without the State of Oregon so that he could get his career back and
continue to support his family.
12. In June of 2008 Plaintiff R Stephens filed a pro se lawsuit against Defendant Nike because he
no longer had any options for reemployment and because his 15 year work history was
destroyed all because he had complained. Plaintiff K and R Stephens were under extreme
financial distress as they had quickly depleted Plaintiff R Stephens meager retirement savings
just trying to survive. Defendant Nike was outraged when Plaintiff R Stephens filed suit
against them because of the nature of his allegations and decided to use Plaintiff Q Stephens
trial to destabilize Plaintiff R Stephens. Defendant Vangelisti Kocher and Defendant
Lachenmeier diligently tried to dig up adverse information about Plaintiff K and R Stephens

as a favor for Nike but discovered nothing. Defendants put together a mock trial designed to
cause the Plaintiffs severe emotional distress so that the Plaintiffs would go crazy with grief
or commit a crime so that Defendant Nike would be absolved of Plaintiff R Stephens lawsuit.
Defendant Nike did not get the desired response therefore in an effort to ultimately punish
Plaintiff R Stephens for complaining and causing so much trouble Defendant Knight gave
Defendant OHSU 100 million dollars to make sure Plaintiff Q Stephens died from her
internal distress and Defendant Portland Police Bureau agreed never to investigate Plaintiff Q
Stephens burn injury or any of the circumstances surrounding the injury.
13. The fact is that Plaintiff K and R Stephens were ill equipped to care for Plaintiff Q Stephens
burn injury because they are not medical professionals in any capacity and had no idea what
they were doing or what they were looking at the entire time that they had cared for Plaintiff
Q Stephens in their home. Plaintiff Q Stephens suffered a very large burn for a tiny 62
pound eight year old child and the actions taken against her on the night of April 12
th
2007
are outrageous. Nobody needed to be worrying about labeling the injury as anything until
Plaintiff Q Stephens had been properly evaluated and stabilized. Sending Plaintiff Q
Stephens home to be treated in an unsterile environment by her parents who are not medical
professionals in any capacity was criminal. Expecting Plaintiff K and R Stephens to be able
to care for and heal Plaintiff Q Stephens burn injury was ridiculous. Plaintiff Q Stephens
burn injury needed far more medical attention than what Plaintiff K and R Stephens were
able to provide. Plaintiff K Stephens and R Stephens diligently sought medical care for
Plaintiff Q Stephens which was repeatedly denied because the Stephens are not white,
wealthy, or related to anyone of importance. The baseless accusations that Defendants have
been spreading about Plaintiff K and R Stephens to be absolved of this horrific hate crime

against Plaintiff Q Stephens is nothing short of disgusting. Defendant Providence and
Defendant OHSU should have followed protocol and treated Plaintiff Q Stephens burn injury
appropriately. Plaintiff Q Stephens was obviously fatally injured and in need of expert
medical attention.
14. Defendant Nike should have just moved Plaintiff R Stephens because that was the right way
to respond to Plaintiff R Stephens complaint. Plaintiff R Stephens was obviously
traumatized about the behavior exhibited by Randy Wolfe. It should have been no problem
for Defendant Nike to elevate the issue and address the matter appropriately. Just because
the Stephens Family is not white, not wealthy, and unrelated to anyone of importance
Defendants have been willing to ignore and hide the facts and attempted to cause the death of
Plaintiff Q Stephens and cover it up. Defendants have subjected the Stephens Family to
prolonged and destabilizing psychological harm as a result of the malicious intentional
campaign to destroy Plaintiff R Stephens and Plaintiff K Stephens and to keep covered up the
abuse, neglect, and attempted murder of Plaintiff Q Stephens.
V. BACKGROUND OF FACTS
15. In March of 2007, Plaintiff Renee Stephens was a footwear designer at Nike, working for
Nikes subsidiary Exeter Brands Group. Plaintiff R. Stephens complained to Nike about
witnessing and being a victim of sexual harassment on the Nike campus by one of his
superiors, Randy Wolfe.
16. On March 9, 2007 Defendant Nike completed an investigation and issued a fact finding
determination that revealed that there was behavior inconsistent with Nike Policy.
17. On March 12, 2007 Plaintiff R. Stephens filed a formal charge of discrimination against Nike
with the Equal Employment Opportunities Commission claiming sex discrimination and

sexual harassment. Plaintiff R. Stephens filed a complaint with the EEOC to help Defendant
Nike understand that it was not appropriate for his work relationship with Randy Wolfe to
continue and that he should be moved to a different department.
18. Defendant Nike told Defendant EEOC that Plaintiff R. Stephens does not have the right to
choose his remedy and that Plaintiff R. Stephens did not even have a right to know if his
allegations were substantiated or if a remedy had even been applied.
19. On March 20, 2007 Plaintiff R. Stephens father passed away of which he informed
Defendant Nike and Plaintiff R. Stephens took two weeks off to attend the funeral.
20. On April 12, 2007, Plaintiff Qadira Stephens was spending the night at the house of
Defendants Todd Burkholder and Aimee McQuiston for an overnight with their daughter
Sophie Burkholder. That night Plaintiff K Stephens attempted to contact plaintiff Q Stephens
so that plaintiff Q Stephens little sister Kamaya Stephens could say goodnight to plaintiff Q
Stephens. Plaintiff K Stephens spoke with defendant McQuiston who stated that plaintiff Q
Stephens had been burned and that plaintiff K Stephens should come over.
21. Plaintiff K. Stephens preceded to Defendants Burkholder/McQuistons home where she was
led down to their basement to find Plaintiff Q. Stephens naked wrapped only in a towel on a
couch, her face swollen and red from crying, and with severe burn on her left leg.
22. Plaintiff K. Stephens brought Plaintiff Q. Stephens home where Plaintiff R. Stephens also
saw the burn sustained by Plaintiff Q. Stephens. Plaintiff K. Stephens contacted her mother,
Mrs. Audrey Lloyd, for advice of what to do and was told to take Plaintiff Q. Stephens to the
hospital.
23. Plaintiff K. Stephens contacted Defendants Burkholder and McQuiston to ask if they would
come to the Stephens residence because plaintiff R Stephens and Plaintiff K Stephens had 3

other small children who were sleeping and could not be left alone and plaintiff Q Stephens
needed to be taken to the hospital right away. Plaintiff R Stephens and Plaintiff K Stephens
left for the hospital immediately after Defendant Todd Burkholder arrived at their home.
Mrs. Audrey Lloyd arrived at the home of plaintiff K and R Stephens shortly after they left
for Providence hospital.
24. Plaintiffs K. and R. Stephens took Plaintiff Q. Stephens to the Emergency Room Department
of Defendant Providence St. Vincents Hospital where she was seen by Defendant Dr. Julie
Andrews.
25. Defendant Andrews diagnosed Plaintiff Q. Stephens with a 10-20%, 2
nd
degree burn on
Plaintiff Q. Stephens left knee. Plaintiff Q. Stephens was seen by Defendant Julie Andrews
who applied silver sulfadiazine cream and gauze wrap to her leg, then discharged her 20
minutes later with orders to apply the same treatment, to give Plaintiff Q. Stephens
acetaminophen with codeine for her pain, and to see her regular doctor for follow-up care.
26. On April 13
th
2007 Plaintiff R. Stephens contacted Defendants Burkholder and McQuiston to
let them know how Plaintiff Q. Stephens was doing and to ask for their homeowners
insurance to ensure Plaintiff Q. Stephens medical expenses would be covered.
27. Defendant Todd Burkholder told Defendant State Farm insurance and Defendant Beth Phipps
that Plaintiff R Stephens and Plaintiff K Stephens asked for his homeowners insurance
because they were just interested in getting money and that they did not care about Plaintiff
Q Stephens.
28. Plaintiff K. Stephens took Plaintiff Q. Stephens to Defendant Oregon Health and Science
University Hospitals Gabriel Park Medical Center that day to have her burns evaluated.

Plaintiff Q. Stephens was seen by Defendant Dr. Sara Tubbesing, as well as several other
unknown doctors and nurses all of whom did nothing to help plaintiff Q Stephens.
29. Defendant Tubbesing and the other individuals did not treat Plaintiff Q. Stephens burn in
any way, only examined it. Then, Defendant Tubbesing ordered Plaintiff K. Stephens to buy
a list of supplies at the medical store and to administer three times daily wound care for
Plaintiff Q. Stephens burn without medical instruction, supervision, or assistance at Plaintiff
K and Plaintiff R Stephens home.
30. Plaintiff K Stephens and Plaintiff R Stephens did as defendant Tubbesing ordered and did
complicated bandage changes on Plaintiff Q Stephens at their home several times a day
without medical instruction, supervision, or assistance.
31. On April 14
th
, 2007 Plaintiff K Stephens called OHSU and spoke with Dr. David Solondz
and told him she felt like she didnt know what she was doing. Dr. David Solondz assured
Plaintiff K Stephens that she was doing everything adequately and that she should just keep
doing what she was doing.
32. On April 16, 2007 Plaintiff K. Stephens notified Defendant Portland Public Schools about
Plaintiff Q. Stephens injury and the circumstances surrounding Plaintiff Q Stephens injury,
and that she would not be returning until she was healed.
33. In late April 2007 Defendant Beth Phipps, a claims adjuster from Defendant State Farm
Insurance Company, visited Plaintiffs K. and R. Stephens home and asked to take pictures of
Plaintiff Q. Stephens burn. Plaintiff K. and R. Stephens were uncomfortable with this visit
and decided to get legal representation for Plaintiff Q. Stephens to make sure that the
situation was being handled appropriately.

34. In early May 2007 Plaintiffs K. and R. Stephens retained Steven P Riedlinger of Susak and
Powell, P.C. to represent Plaintiff Q. Stephens.
35. On approximately May 18, 2007 Defendant Kocher contacted Plaintiff K. Stephens and
convinced her that she needed a special burn attorney to represent Plaintiff Q. Stephens.
After that conversation Plaintiff K. and R. Stephens decided to switch Plaintiff Q. Stephens
representation to the firm of Vangelisti Kocher, LLP.
36. Defendant Providence, Defendant OHSU, Defendant Portland Public Schools, Defendant
Vangelisti Kocher, Defendant Lachenmeier and Defendant Steven P Riedlinger are all
mandatory reporters and had a legal responsibility to report plaintiff Q Stephens burn injury
to the proper authorities.
37. On August 16, 2007 Plaintiff R. Stephens filed his second charge of discrimination against
Defendant Nike claiming retaliation because Defendant Nike told Plaintiff R Stephens that he
was being laid off because all NASCAR positions were being eliminated Plaintiff R.
Stephens position was not specific to NASCAR. Plaintiff R Stephens was an Exeter
employee working on all aspects of the Exeter business. Plaintiff R Stephens last day at
Defendant Nikes corporation was September 28, 2007.
38. Plaintiff R Stephens applied for multiple positions within and without Nike but he could no
longer get an interview or job offer of any kind in his industry.
39. In October of 2007 Plaintiff R. and K. Stephens youngest daughter was stricken with a rare
life threatening auto-immune disorder called Kawasakis Syndrome and hospitalized at
Emanuel Hospital for treatment. Plaintiff R Stephens liquidated his 401 K in order to cobra
his health insurance to cover Alma Stephenss hospital stay, treatment, and any further
medical expenses that might arise out of her medical condition.

40. On November 15
th
Defendant Nike announced the sale of the Starter brand to Iconix.
Defendant Nike guaranteed the loan of 60 million dollars for Iconix and Defendant Nike and
Iconix agreed to indemnify each other in the event that anything went wrong with the deal.
41. On November 17, 2007 Plaintiff R. Stephens filed his third charge of discrimination against
Nike claiming defamation, because he could no longer get work in his industry.
42. On November 17
th
2007 Defendant Kocher contacted Plaintiff K Stephens and told her that
Plaintiff Q Stephens needed a guardian ad litem and that Plaintiff K Stephens had to be her
guardian ad litem in order to move forward on behalf of Plaintiff Q Stephens. Defendant
Vangelisti Kocher had a trained guardian ad litem on the payroll by the name of Patricia
Piazza but did not inform Plaintiff K and R Stephens that they had any other options.
43. On November 21, 2007, Defendant Kocher petitioned to have Plaintiff K. Stephens
appointed the guardian ad litem for Plaintiff Q. Stephens which was granted by Defendant
Dale R. Koch. Defendant Kocher filed suit against Defendant McQuiston in Multnomah
County Circuit Court. Defendant Rudy Lachenmeier appeared as counsel for Defendant
McQuiston, Defendant Burkholder and Defendant State Farm to help Vangelisti Kocher
cover up the abuse and neglect of Plaintiff Q Stephens.
44. In January of 2008 Defendant Nike told the EEOC that they had shutdown Exeter Brands
Group LLC and that was the actual reason why Plaintiff R Stephens was laid off from Nike.
45. On January 22, 2008 Defendant OHSU ran a full metabolic workup on Plaintiff Q Stephens
and discovered that she was in internal distress and suffering from sepsis, liver damage, low
white blood cell count, and kidney distress. Defendant OHSU did not treat Plaintiff Q
Stephens and did not inform Plaintiff K and R Stephens of her condition.

46. On January 30, 2008 the EEOC dismissed all of Plaintiff R. Stephens discrimination charges
with indeterminate findings.
47. On February 26, 2008 the depositions of Defendant Burkholder, Defendant McQuiston,
Sophie Burkholder, Plaintiff Q. Stephens, and Plaintiff K. Stephens were taken. Defendant
Kocher advised Plaintiff K. Stephens not to attend the Defendants depositions and she did
not attend them.
48. On April 11, 2008 Plaintiff K, R, and Q. Stephens attended a mediation conference with
Defendant Lachenmeier held by Defendant John Barker. Defendant Kocher counseled
Plaintiff K Stephens to walk out of the mediation.
49. On June 6, 2008 Plaintiff R. Stephens filed suit against Nike/Exeter Brands Group for sex
discrimination, sexual harassment, retaliation, and defamation.
50. On June 30, 2008 Defendant Lachenmeier deposed Plaintiff R. Stephens for several hours.
51. On August 11 and 12, 2008 Plaintiff Q Stephens went to trial against Defendant McQuiston,
presided over by Defendant Judge Michael McShane.
52. Defendant Burkholder and Defendant McQuiston admitted in sworn testimony to playing a
naked game in the bathroom called little house on the prairie with Plaintiff Q. Stephens and
Sophie Burkholder.
53. Defendant McQuiston testified that she burned Plaintiff Q. Stephens with scolding hot water
from a tea kettle.
54. There were no law enforcement officials, doctors, expert witnesses, or anyone who testified
in the trial besides Defendant Burkholder, Defendant McQuiston, Sophie Burkholder,
Plaintiff K. Stephens, and Plaintiff R. Stephens.
55. Plaintiff Q. Stephens did not attend the trial.

56. Plaintiff Q. Stephens deposition was read to the court by opposing counsel, Defendant Betsy
Fernly.
57. On August 12, 2008 Defendant Susan Glosser, presiding juror, returned a no negligence
verdict in favor of Defendant McQuiston.
58. On August 13, 2008, Defendant Kocher told Plaintiff K. Stephens to button it down and
walk away after having a meeting with her and Plaintiff R. Stephens at their home.
59. On approximately August 14, 2008 Plaintiff K. and R. Stephens contacted Portland Police
Bureau and Defendant Officer Mulberry responded. Plaintiff K. and R. Stephens were
informed by Defendant Mulberry that they were not allowed to file a police report.
60. Plaintiff K. Stephens contacted the District Attorneys Office and was told that she could not
press charges without a police investigation.
61. On August 16, 2008 Plaintiff R. Stephens took Plaintiff Q. Stephens to the downtown
Portland Police station and reported Plaintiff Q. Stephens burn injury to Defendant Officer
Miller. Defendant Miller took the report and told Plaintiff R Stephens that what Q Stephens
had experienced was at least reckless endangerment.
62. Plaintiff K and R Stephens pulled Plaintiff Q Stephens court file to try to figure out what had
happened. Defendant Paul Schoen told Plaintiff K and R Stephens that there was no record
of the evidence that went back to the jury.
63. Plaintiff K Stephens visited the home of Defendant Glosser in an attempt to figure out what
evidence had gone back to the jury at trial. Defendant Glosser was very nasty to Plaintiff K
Stephens and said that Plaintiff K Stephens was crazy and that Defendant McQuiston and
Defendant Burkholder had paid all of Plaintiff Q Stephens medical bills. Defendant Glosser
slammed the door in Plaintiff K Stephens face threatening to call the police if Plaintiff K

Stephens did not get off her property. Defendant Glossers husband reiterated to Plaintiff K
Stephens that Defendant McQuiston and Defendant Burkholder had done nothing wrong and
that she should leave the property and Plaintiff K Stephens complied.
64. Plaintiff K. Stephens contacted Defendant Sgt. Dan Lui who is the head of the child abuse
team for the Portland Police Bureau and described what happened to Plaintiff Q. Stephens.
Defendant Sgt. Dan Lui firmly told Plaintiff K Stephens that the Portland Police do not
investigate this type of thing, Defendant Lui was rude and argumentative with Plaintiff K.
Stephens and terminated their phone conversation by hanging up on her.
65. After the verdict was rendered in Plaintiff Q. Stephens case, Defendant Kocher refused to
prosecute her case any further.
66. On August 18, 2008 Plaintiff K. Stephens filed a bar complaint against Defendant Kocher
alleging that he was incompetent or criminally negligent.
67. On August 28, 2008 Defendant Firdousi Chowdhury conducted a home visit and interviewed
Plaintiff Q. Stephens. Defendant Chowdhury did not interview Defendant Burkholder,
Defendant McQuiston, or Sophie Burkholder.
68. Plaintiff K. Stephens retained Steven P. Reidlinger of Susak and Powell to motion for a new
trial, which was denied with extreme bias by Defendant McShane on August 29, 2008.
69. Plaintiff K and R Stephens spoke with Robin Morrison Principal of Hayhurst Elementary
School and a representative for Portland Public schools about Plaintiff Q Stephens burn
injury and the improper use Odyssey Program materials as a defense at the trial of Plaintiff Q
Stephens and to inform the school that Stephens children should have no contact with
Defendant Burkholder and Defendant McQuiston. Defendant Portland Public Schools stated
that they would move Plaintiff Q Stephens out of the Odyssey Program and speak to

Defendant Todd Burkholder and Defendant McQuiston. Defendant Portland Public Schools
stated that they could not ask Defendants Todd Burkholder and Aimee McQuiston to stop
volunteering at the school, and that they could not inform Plaintiff K and R Stephens about
any conversation that they had with Defendants Todd Burkholder and Aimee McQuiston, or
if any corrective action was taken in the matter. Defendant Portland Public Schools
continued to allow Defendant Burkholder and Defendant McQuiston to volunteer at Hayhurst
Elementary School despite Plaintiff Q Stephens burn injury and despite being informed of
the circumstances surrounding the injury.
70. Plaintiff K and R Stephens enrolled Plaintiff Q Stephens into counseling at Lifeworks for the
entire year that Plaintiff Q Stephens attended the 4
th
grade.
71. On September 2, 2008 Plaintiff R. Stephens filed his third amended complaint against
Defendant Nike/Exeter Brands claiming specifically:
1.
Plaintiff is a resident and citizen of the State of Oregon. Plaintiff has been
married for ten years and has four children.
2.
Defendant is an Oregon corporation and a wholly owned subsidiary of an
Oregon corporation who does business in the County of Washington. At all
material times Defendants acted through agents and employees who at all material
times acted within the course and scope of their agency and employment for
Defendants.
3.
Plaintiff worked for Defendant from February 12th, 2001 until September
29th, 2007 when his position was eliminated. Plaintiffs position was changed on
February 20th, 2005 from a Color Designer I at Nike, Inc. to a Footwear Designer
I at Exeter Brands Group, LLC, which was his last position, held with the
corporation.
5.
On February 2, 2007 Plaintiff entered a storage room of his office space to
help Randy Wolfe, Senior Designer and Mentor/Supervisor to Plaintiff, mount
design boards for a presentation. Defendant Wolfe was speaking with Cory

McCullagh, also Senior Designer and Mentor/Supervisor to Plaintiff, when
Plaintiff interrupted and asked, Should I start mounting? Defendant Wolfe said,
Hold on, then proceeded to unbuckle his belt, pull down his pants (exposing his
underwear,) bent over a table presenting his buttocks to Plaintiff in an apparent
solicitation of a sexual advance, and said, Yah, start mounting! Plaintiff was
shocked and said, Sorry, Ill choose my words more carefully next time. Then
Plaintiff left the room.
6.
On or about February 6, 2007 Plaintiff was speaking with Defendant
McCullagh in the passage way out front of his cubicle. Defendant McCullagh was
leaning over the island table in the passage way when without warning Defendant
Wolfe approached him from behind, grabbed Defendant McCullagh by his hips,
and began aggressively and repeatedly thrusting his genital area into and against
Defendant McCullaghs buttocks, mimicking anal intercourse. Plaintiff was
appalled and disgusted. Later that week, Defendant McCullagh and Defendant
Wolfe were leaving a meeting in a room parallel to Plaintiffs cubicle. Defendant
McCullagh momentarily stopped in front of the island table to answer one of the
Plaintiffs questions. Defendant Wolfe approached Defendant McCullagh from
behind to re-enter the meeting room. Defendant Wolfe cocked his arm backward
and forcefully swung his hand forward and upward into the space between
Defendant McCullaghs buttocks violently groping him. The Plaintiff was
shocked and disturbed.
7.
On or about February 15, 2007 Plaintiff was helping Defendant Wolfe
organize the storage room of their office space when Defendant McCullagh
entered to begin a conversation with Defendant Wolfe. Defendant McCullagh
turned away from Defendant Wolfe to comment to Plaintiff and
Defendant Wolfe grabbed Defendant McCullagh by his hips, and began
aggressively and repeatedly thrusting his genital area into and against Defendant
McCullaghs buttocks, again mimicking anal intercourse. As Defendant Wolfe
continued his inappropriate act Defendant McCullagh said, I can feel your little
Elvis. Plaintiff was intensely disturbed and became very anxious for his own
personal safety in the work place.
8.
February 28, 2007 Plaintiff entered the storage room where Defendant
Wolfe and Defendant McCullagh were speaking to ask them a technical question
about a project the Plaintiff was working on. Defendant Wolfe put on a jogging
jacket and pretended to warm up for a run by jumping up and down and stretching
his legs. Defendant Wolfe approached Plaintiff from behind and firmly grabbed
Plaintiff by his hips and attempted to thrust his genital area into and against

Plaintiffs buttocks. Plaintiff put his elbow in between Defendant Wolfe and
himself, and then stepped back toward him off. Plaintiff defiantly told Defendant
Wolfe, We are not going there! Defendant Wolfe threatened the Plaintiff as he
turned to Defendant McCullagh and stated, Ill just try it again when he turns
thirty! Then, he turned to the Plaintiff and said, Youre too virile of a young
man to not have tried sleeping with another man! The Plaintiff affirmed, I
would never do that, and then left the room. Plaintiff was extremely intimidated
and disturbed.
9.
The Plaintiff avoided interaction with Defendant Wolfe until March 2,
2007. At the end of the work day as the Plaintiff was walking down the hall
talking on his cell phone to his wife and preparing to exit the building Defendant
Wolfe approached him from behind. Defendant Wolfe cupped Plaintiffs left
buttock with his hand and slid his hand upward with a caressing motion to the
small of Plaintiffs back. The Plaintiff pushed Defendant Wolfes hand away and
said, No! Defendant Wolfe raised his arms and stuck them out at his sides and
said, What? Plaintiff was very distressed and intimidated, said nothing and left.
10.
On March 5th, 2007 Plaintiff decided to tell his manager Mac Mcdevitt
what happened. Plaintiff typed a written statement detailing what Defendant
Wolfe did to Plaintiff and read it to Defendant Mcdevitt in Defendant McDevitts
office. Defendant Mcdevitt immediately called HR Director Mary Brunke into his
office where Plaintiff recounted the story to her. Plaintiff was very nervous and
frightened. Defendant Brunke called Melissa Marks, an Employee Relations
Director for Nike Inc., and they set up a fact finding meeting with Plaintiff for
March 7th, 2007. In that meeting Plaintiff described to both Defendant Brunke
and Defendant Marks about what Defendant Wolfe did to Defendant McCullagh
and himself.

12.
On March 9th, 2007 Plaintiff met with Defendant Brunke for a follow up
meeting. She presented Plaintiff with a closure letter written by Defendant Marks
that was unsigned and misleading of the allegations. Defendant Brunke told
Plaintiff that they handled the matter and would not disclose how to Plaintiff.
Defendant Brunke told Plaintiff they determined from their investigation that it
was just roughhousing and that Defendant Wolfe did not realize he was
offending Plaintiff. She told Plaintiff after he inquired that they would not
transfer him or Defendant Wolfe to another department. Plaintiff informed
Defendant Brunke that he no longer felt comfortable with the conditions in his
work place environment and no longer wanted to work with Defendant Wolfe.

Defendants failed to inform Plaintiff that the validity of his allegations was in
question effectively forfeiting Plaintiffs ability to challenge the findings of the
investigation.
13.
By defining Plaintiff allegations as roughhousing the Defendants
conducting the fact finding investigation recklessly down-played Plaintiffs
allegations. This action resulted in the Defendants failure to involve the proper
authorities and/or mental health professionals. Plaintiff asserts that proper
qualified personnel with experience in dealing with male victims of sexual
harassment could have conducted a thorough investigation, interviewed all
potential witnesses inside the work area, and determined the actual validity of
Plaintiffs allegations; and made appropriate corrective recommendations to
ensure a productive and positive work environment for all involved parties.
14.
Plaintiff asserts that he was subjected to repeated displays of sexually
aggressive and predatory behavior. Plaintiff contends that if he were female,
Defendants would not have categorized such behaviors complained about as
roughhousing. Plaintiffs complaint would have been taken seriously and a
thorough investigation would have been conducted, with a different remedy
applied. Plaintiff felt he had to comply with Defendants decision of returning
Plaintiff to work with Defendant Wolfe or risk losing his job and the ability to
support his family. Plaintiff drove to Seattle on March 12th, 2007 and filed a
charge of sex discrimination with the Equal Employment Opportunity
Commission against Defendants.
15.
When Plaintiff returned to work he avoided any interaction with
Defendant Wolfe. Plaintiff felt extremely intimidated by the entire circumstance
and reiterated to Defendants that he no longer felt safe or comfortable in his work
environment. Plaintiff requested that all communication between Defendant
Wolfe and himself be handled by Management. On March 19th, 2007 Plaintiff
emailed Defendant Marks asking her to correct the closure letter to reflect the
actual alleged events and to sign the letter. Plaintiffs father passed away on
March 20th, 2007. Plaintiff took two weeks off to attend the out of state funeral.
17.
Plaintiff returned to work on April 2nd, 2007. Defendant Mcdevitt
verbally reassigned Plaintiff to new mentor/supervisor Shawn Wenzel because he
complained about Defendant Wolfe. Plaintiff continued to support the Starter
Brand, the Tailwind Brand, the Elton Brand Basketball initiative within the
Starter Brand, and began supporting the new NASCAR initiative also within the
Starter Brand. On April 15th, 2007 Donna Morrow, General Manager for

Tailwind, presented Plaintiff with a Milestone Award for his help with the
Tailwind Brand.
18.
Plaintiff worked with and in close proximity to alleged aggressor, witness,
and management who had direct knowledge of Plaintiffs protected activity and
full details of allegations. Defendant Mcdevitt, Defendant McCullagh, and other
employees (including, but not limited to the President and C. E. O. of Exeter
Brands Group, Clare Hamill) continued to verbally harass Plaintiff by their
persistent use of the name Big Daddy when referring to Plaintiffs alleged
aggressor. Defendants allowed Defendant Wolfe to retain offensive paraphernalia
on his desk and allowed him to refer to himself as Big Daddy.
19.
On August 13th, 2007 Plaintiff was verbally informed by Defendant
Hamill, Defendant Mcdevitt, and Defendant Brunke that the NASCAR initiative
was being divested, and that the Plaintiffs position was being eliminated.
Defendant Brunke later reiterated to Plaintiff in subsequent emails that his
position was being eliminated because all NASCAR positions were being
eliminated. Plaintiffs position was not a NASCAR position. Plaintiffs position
was as an Exeter Foot-wear Designer I, supporting all aspects of the Exeter
Footwear business.
20.
Plaintiff met with Defendant Brunke on August 14th, 2007 and was told
that he should begin searching for employment outside of the corporation.
Plaintiff was not offered a transfer. Plaintiff was also encouraged by Defendant
Mcdevitt, Defendant Wenzel, and Eric Happel (a Strategic Planner for Exeter
Brands) to seek work outside of the corporation. Plaintiff sent resumes to Ron
Vasquez (HR Director), Lisa Olivia (Nike Design Recruiter), Ginny Hopkirk (HR
Director), and Peter Hudson (Nike Design Director) informing them of his job
loss and his desire to stay employed at Nike. Plaintiff met with several Nike
business leads including Ginny Hopkirk, Scott Leclair (Action Sports General
Manager), Ted Baldeere (Digital Design Studio Director), Skip Lei (Innovation
Lead for Nike Affiliates), E. Scott Morris (Cleated Design Director), and Karen
Reuther (Global Color Design Director) in an effort to secure employment.
Plaintiff was told that there was no head-count for him despite the fact that Nike
was hiring and Plaintiffs exceptional work history with the corporation.
21.
Plaintiff applied for three entry level positions during August 2007 which
he qualified for and was denied. Defendant Marks sent Plaintiff a formal
termination letter on August 26th, 2007. Plaintiff requested a copy of his
personnel file and on August 28th, 2007 received a copy which was missing the

last four years of his reviews and other documents. Plaintiff filed a charge of
retaliation with the Equal Employment Opportunity Commission on August 29th,
2007.
22.
On September 25th, 2007 Defendant Olivia offered Plaintiff an invitation
to apply for a design position that he did not qualify for. Plaintiff declined the
invitation to apply to that position.
23.
Plaintiff was unable to accept Defendants severance package because it
was contingent on a release of claims against Defendants. Plaintiff had two open
EEOC charges under investigation when his employment with the corporation
ended.
24.
Since Plaintiffs last day at Defendants corporation, Plaintiff has applied
for six additional positions that he qualified for within Nike, Inc. Plaintiff has
received no response (except for the automated responses informing him that his
applications were received) from Defendants in regards to any of those positions.
25.
As a result of Defendants discrimination, Plaintiff suffered intimidation,
humiliation, and degradation. Due to Plaintiffs loss of income and career,
Plaintiff and his family have and will continue to suffer emotional distress, mental
anguish, and loss of quality of life. Plaintiff liquidated his 401K in order to
support his family after his loss of income. Plaintiff had to Cobra his health
insurance for several months when his youngest daughter was stricken with a life
threatening illness shortly after his employment with Defendants corporation
ended. Plaintiff has been unable to secure employment. Plaintiff and his family
are currently fully dependent on state assistance for food, cash, and health
insurance. Plaintiff does not want this to happen to anyone else.

72. On October 13, 2008 Plaintiff K. Stephens sent a comprehensive letter to Defendant Rosie
Sizer, alleging that Defendant Kocher and Lachenmeier conspired to cover up a crime and
requested a police investigation.
73. On October 29, 2008 Plaintiff K. Stephens complaint was reviewed by Defendant Officer
John Eckhart and Defendant Officer Bret Smith and Defendant Portland Police Bureau
refused to investigate any of the issues brought by Plaintiff K. Stephens.

74. On October 29, 2008 Defendant Phil Knight donated $100 million dollars to Oregon Health
and Science University Hospital.
75. On November 6, 2008 Defendant Charlie G. Jenkins closed Plaintiff Q. Stephens DHS case
as unable to determine.
76. Plaintiff K. Stephens contacted numerous local and state officials about what happened to her
daughter and the police bureaus failure to investigate and every state and local official that
Plaintiff K. Stephens contacted declined to help her or Plaintiff Q. Stephens.
77. On November 12, 2008 Defendant Reidlinger filed a notice of appeal on Plaintiff Q.
Stephens behalf.
78. On November 12, 2008 Defendant P.K. Runkles-Pearson and Defendant A. J. Pederson from
Stoel Rives, LLP, defense counsel for Nike, began deposing/interrogating Plaintiff R.
Stephens for a two day period on camera. The Defendants questioned Plaintiff R. Stephens
extensively about his time at Nike, his entire life, his religion, and the lawsuit involving
Plaintiff K. and Q. Stephens against Defendant McQuiston.
79. On November 13, 2008 Executive Assistant for the Oregon Department of Justice, Defendant
Jacob Weigler, stated in a letter to Plaintiff K. Stephens that the ODOJ has no authority to
force the Portland Police to do an investigation into Plaintiff Q. Stephens burn injury.
80. On November 17, 2008 Assistant General Counsel for the Oregon State Bar, Defendant Scott
A. Morrill dismissed Plaintiff K. Stephens Bar Complaint against Defendant Kocher.
81. Plaintiff K. Stephens filed a judicial fitness complaint for willful misconduct against
Defendant McShane which was reviewed by the Board of Judicial Fitness on December 12,
2008 and dismissed on December 26, 2008.

82. Plaintiff R. Stephens deposed Claire Hamill, CEO of Exeter Brands Group, LLC on
December 17, 2008; Cory McCullagh and Mary Brunke on December 18, 2008; Defendant
Randy Wolfe January 7, 2009; Richard McDevitt and Melissa Marks on January 8, 2009; and
Allison Daugherty on January 9, 2009.
83. On January 7, 2009 Defendant P.K. Runkles-Pearson and A. J. Pederson deposed Plaintiff K.
Stephens.
84. On January 7, 2009 Defendant P.K. Runkles-Pearson while representing Mr. Wolfe in a
deposition at the offices of Stoel Rives, LLP jumped across the table and snatched Plaintiff
R. Stephens personal recorder and refused to return it until he agreed to let all the
information on it be erased.
85. On January 30, 2009 Plaintiff K. and R. Stephens attended a settlement conference with
Defendant Nike at Washington County Circuit Court presided over by Judge Mark Gardner
and Defendant Nike told Plaintiff R. Stephens to never apply again to their company. Judge
Gardner denied Plaintiff R. Stephens counsel when he verbally asked for it at the settlement
conference.
86. On February 2, 2009 Defendant Sylvia E. Stevens, General Counsel for the Oregon State
Bar, issued a letter closing Plaintiff K. Stephens Bar Complaint against Defendant Kocher.
87. On February 17, 2009 Defendant Stoel Rives, LLP filed its motion for summary judgment
against Plaintiff R. Stephens and on March 9, 2009 Plaintiff R. Stephens filed a
comprehensive opposition to Defendant Nikes motion.
88. On March 30, 2009 oral arguments were heard before Defendant Judge Donald R.
Letourneau and he granted Defendant Nikes motion for summary judgment without issuing
a legal opinion or giving any explanation.

89. On March 11, 2009 Plaintiff K. Stephens filed a complaint with the Independent Police
Review and they concurred with the Internal Affairs Department not to investigate plaintiff Q
Stephens burn injury, and then stated that Plaintiff K. Stephens concerns were not appealable
to the Citizens Review Board because there was no formal investigation.
90. On May 26, 2009 Defendant Letourneau dismissed without opinion and with prejudice
Plaintiff R. Stephens discrimination lawsuit against Defendant Nike/Exeter.
91. On June 2, 2009 Internal Affairs Division declined to investigate the burn injury or the
circumstances surrounding Plaintiff Q. Stephens trial.
92. On July 24, 2009 Plaintiff K. Stephens retained Defendant Andy Simrin to represent Plaintiff
Q. Stephens to appeal Defendant McShanes judgment and in September of 2009 Defendant
Simrin filed the opening brief.
93. On August 6, 2010 Plaintiff R. Stephens filed his appeal against Defendant Nike.
94. On July 14, 2010 the Defendants Judge Schuman, Judge Wollheim, and Judge Rosenblum of
the Oregon Appellate Court affirmed Defendant McShanes decision without opinion.
95. Plaintiff K. Stephens motioned for appointment of counsel for Plaintiff Q. Stephens to
petition the Oregon Supreme Court for review and was denied on September 24, 2010.
96. Plaintiff K. Stephens, on her own, petitioned the Oregon Supreme Court for review of
Plaintiff Q. Stephens appeal.
97. On December 3, 2010 Defendants Judge Haselton, Judge Armstrong, and Judge Duncan of
the Oregon Court of Appeals affirmed the judgment of Defendant Letourneau without
opinion and while all of the material facts were at issue.
98. On December 23, 2010 Defendant Paul J. De Muniz of the Oregon Supreme Court declined
to hear Plaintiff Q. Stephens petition for review.

99. In 2010 Plaintiff R. Stephens filed three additional charges of discrimination against
Defendant Nike with the Equal Employment Opportunities Commission claiming race
discrimination and retaliation.
100. In the summer of 2010 Plaintiff K. Stephens discovered that she was not qualified to have
been appointed Plaintiff Q. Stephens guardian ad litem.
101. In August of 2010 Plaintiff K Stephens filed a lawsuit claiming legal malpractice,
professional negligence, and emotional distress against Vangelisti Kocher, LLP in 2010.
Defendant Callahan appeared as counsel for Defendant Vangelisti Kocher.
102. On March 8, 2011 Plaintiff K. Stephens discovered that the Oregon Department of
Human Services closed Plaintiff Q. Stephens investigation as unable to determine for child
abuse on November 6, 2008. Plaintiff K Stephens requested DHS reopen Plaintiff Q
Stephens burn injury case and make a determination but DHS refused.
103. On March 30, 2011 the Portland Police Records Department denied Plaintiff K. Stephens
Request for Plaintiff Q. Stephens police report on the grounds that the report contained
reports of child abuse.
104. On April 7, 2011 Defendants Kocher and Vangelisti through counsel denied the majority
of the Plaintiff K Stephens allegations and filed a motion for summary judgment on Plaintiff
K Stephens third amended complaint.
105. On April 7, 2011 Defendant De Muniz declined to hear Plaintiff R. Stephens petition for
Oregon Supreme Court review
106. Plaintiff K Stephens filed a comprehensive opposition to summary judgment complete
with testimony and evidence to support her arguments, claims, and allegations on May 16,
2011.

107. On May 25, 2011 Defendant Rees heard oral arguments on the defendants motion for
summary judgment and granted the motion in part and denied it in part without opinion and
directed the plaintiff to amend her complaint.
108. Plaintiff K Stephens filed her fourth amended complaint on May 27, 2011 which added
additional claims of intentional, reckless, and negligent infliction of emotional distress, and
breach of fiduciary.
109. On June 30, 2011 the EEOC determined that Defendant Nike had violated Plaintiff R.
Stephens civil rights but rescinded the determination shortly thereafter.
110. In the summer of 2011 the EEOC dismissed Plaintiff R. Stephens additional charges of
discrimination based on race and retaliation with three more indeterminate findings.
111. Defendant Callahan filed a motion to dismiss the allegations in Plaintiff K Stephens
fourth amended complaint on June 10, 2011.
112. Defendant Rees granted Defendant Callahans motion on July 13, 2011 in whole without
legal opinion. Defendant Rees inserted his personal opinion about the validity of some of the
plaintiffs allegations with extreme bias, and directed the plaintiff to amend her complaint
113. On July 17, 2011 Plaintiff R. Stephens filed a federal lawsuit, docket #3 11-CV-736-HU,
against Defendant Nike based on his fourth, fifth, and sixth EEOC charges.
114. Plaintiff K. Stephens filed her fifth amended complaint against Defendant Vangelisti
Kocher on July 29, 2011.
115. Defendant Callahan filed his motion to strike the allegations in Plaintiff K. Stephens
fifth amended complaint on August 12, 2011.

116. On August 15, 2011 Plaintiff R. Stephens filed a federal lawsuit, docket #3:11-CV-1013-
HU, against the State of Oregon as well as all the judges who oversaw the proceedings in his
state case against Nike/Exeter.
117. Plaintiff K Stephens and Plaintiff R Stephens convened with Defendant Maurer,
Defendant Callahan, and Defendant Kocher for a status update conference on August 15,
2011.
118. Defendant Maurer attempted settlement negotiations which failed and she reassigned the
case to Defendant Nelson based on Plaintiff Stephens informing her that she filed a judicial
fitness complaint against Defendant Rees.
119. Defendant Nelson heard and granted, without opinion, Defendant Callahans motion to
strike the allegations in Plaintiff K. Stephens fifth amended complaint on September 14,
2011.
120. Plaintiff K. Stephens filed a judicial fitness complaint against defendant Nelson alleging
that she was attempting to cover up the abuse of Plaintiff Q. Stephens. Defendant Nelson
refused to recuse herself from Plaintiff K Stephens lawsuit and the judicial board of fitness
dismissed Plaintiff K Stephens complaint without explanation.
121. Plaintiff K Stephens filed a motion to reconsider Defendant Nelsons ruling on
September 30, 2011, specifically requesting that Defendant Nelson explain why and how she
granted Defendant Callahans motion to strike.
122. Defendant Nelson denied the plaintiffs motion without legal opinion on November 16,
2011 and directed her to amend her complaint.
123. Plaintiff K. Stephens filed her sixth amended complaint on October 7, 2011, which added
Plaintiff Q Stephens and her claims as a plaintiff by and through her duly appointed guardian

ad litem Karellen Stephens. The sixth amended complaint also added Defendant Kocher and
Defendant Vangelisti as individual defendants.

124. Plaintiffs K. and R. Stephens requested the Federal Bureau of Investigation investigate
the circumstances surrounding Plaintiff Q. Stephens injury and how it was handled by the
legal system.
125. On March 14, 2011 Defendant Glenn G. Norling on behalf of the F.B.I. refused to
investigate and told the plaintiffs to never contact the F.B.I. again.
126. Plaintiff K. and R. Stephens reported to the Office of the Inspector General that the State
of Oregon was covering up child abuse and that the local F.B.I. was refusing to investigate
and the Office of the Inspector General refused to investigate any of the issues brought by
Plaintiff K and R Stephens.
127. On July 5, 2011 Plaintiff Q. Stephens was diagnosed with Type 1 Diabetes after being
rushed to Emmanuel hospital in full blown ketoacidosis.
128. In the summer of 2011 Plaintiff K. and R. Stephens visited Joseph Pulito, M.D., where he
told them that Plaintiff Q. Stephens should have been transferred to the Oregon Burn Center
for treatment based on the diagnosis of the ER report from Providence St. Vincent Hospital
and from OHSU Hospital.
129. Plaintiff K Stephens contacted The American Burn Association and was told that based
on the recommendations of the American Burn association plaintiff Q Stephens should have
been transferred to the Oregon Burn Center for treatment.
130. Plaintiff K. Stephens filed complaints against all doctors involved and Defendants OHSU
and Providence Hospital with the Defendant Oregon Medical Board. The Oregon Medical
Board dismissed the complaints without an explanation.

131. On April 22 and May 2, 2011 in a depositions held by Plaintiff K. Stephens, Defendant
Kocher testified under penalty of perjury, that he served on a committee with Defendant Rex
Burkholder, Defendant Todd Burkholders brother an Oregon politician; he testified that he
did work for the law firm that is defending Nike against Plaintiff R. Stephens.
132. On January 13, 2012 Defendant Callahan filed a motion in the current county case
#1008-1100 limiting Plaintiff K. Stephens from submitting evidence or commenting at trial
on any of the emotional distress she experienced; Defendant Kochers connection to
Defendant Rex Burkholder; Plaintiff K. Stephens appointment as Plaintiff Q. Stephens
guardian ad litem; the fact that Defendant Kocher did not report Plaintiff Q. Stephens injury
to the police; the fact that Defendant Kocher used Plaintiff K. Stephens medical records in
Plaintiff Q. Stephens civil trial; any of Defendant Kochers conduct at Plaintiff Q. Stephens
civil trial; and the fact that this was a matter of child abuse or that there was a conspiracy to
cover it up which was granted by Defendant Nelson without, reason, explanation or opinion.
133. On January 17
th
and 18
th
Defendant Nelson, Defendant Callahan, Defendant Vangelisti
Kocher, Defendant McQuiston, Defendant Burkholder, and Defendant Lachenmeier
attempted to hold trial proceedings at Multnomah County Courthouse to force Plaintiff K
Stephens to amend her complaint and go to trial against Defendant Vangelisti Kocher with
the amended allegations which included none of Plaintiff K Stephens allegations only a claim
to recover the money Plaintiffs paid Defendant Andy Simrin to appeal Qadiras case.
134. On January 17
th
Plaintiff K Stephens informed Defendant Callahan and Defendant
Nelson via email that she would not be participating in the proceedings because she does not
engage in covering up crimes.

135. Plaintiff Q. Stephens was denied proper medical attention from Defendants OHSU
Hospital and Providence Hospital; denied an investigation from every authority official; has
not received compensation in any form from anyone; and has been unable to get any legal
assistance. Plaintiff Q. Stephens is 13 years old.
136. Defendant Nike filed documents with the EEOC and the Washington County Court
House stating that Plaintiff R. Stephens layoff was due to the shutdown of Exeter Brands
Group, LLC, but to this day Exeter Brands Group, LLC is still an active business as so
documented by the New York State Department.
137. On January 22, 2012 Plaintiffs K. and R. Stephens discovered that Defendant OHSU
Hospital had knowledge based on a comprehensive metabolic test taken on January 22 2008
that Plaintiff Q. Stephens was experiencing internal distress and severe sepsis after her burn
injury occurred. Plaintiff K and R Stephens tried to report the crime to Portland Police, FBI,
and informed Portland Public Schools of the matter. Portland Police and the FBI hung up on
the Stephens repeatedly and refused to investigate or even speak with the Stephens Family.
VI. STATEMENT OF CLAIMS AND ALLEGATIONS
138. Defendants conspired to deprive Plaintiffs of rights and sought to inflict severe
debilitating emotional distress onto Plaintiffs because Plaintiffs are not white, wealthy, or
related to anyone of importance, because Plaintiff R. Stephens complained and pursued civil
action against Nike, Inc. and because defendants intended to cover up the crime of child
abuse perpetrated by Aimee McQuiston and Todd Burkholder.
139. Defendant Vangelisti Kocher intended to cause the Plaintiff K. Stephens severe
emotional distress by not advising her that her private medical information was breached in
Plaintiff Q. Stephens medical report.

140. Defendant Vangelisti Kocher intended not to allow the Plaintiff K. Stephens to sit in on
or discuss the depositions of Sophie Burkholder, Todd Burkholder, or Aimee McQuiston
because Defendant Vangelisti Kocher intended to cause Plaintiffs severe emotional distress
at trial by shocking them with the testimony of Todd Burkholder and Aimee McQuiston.
141. Defendant Vangelisti Kocher intended to cause the Plaintiffs severe emotional distress by
advising them to go to trial without the Qadira Stephens, the key witness, so that Qadira
would lose her case.
142. Defendants intended to cause the plaintiff severe emotional distress by not informing the
Plaintiffs of Ms. McQuistons denial of liability and intentionally left Todd Burkholder, a
responsible party, off of the complaint, because the Defendants intended for Qadira Stephens
to receive nothing for her injuries.
143. Defendants intended not to inform the Plaintiffs they were going to conspire with Rudy
Lachenmeier to cover up a crime, so that it would cause the Plaintiffs emotional distress
when they could no longer seek criminal prosecution against Qadiras abusers.
144. Defendant Kocher and Defendant Vangelisti Kocher failed to inform the plaintiff that
they worked for Stoel Rives, LLP, which was at the time defending a legal action against the
plaintiffs husband Renee Stephens which was a serious conflict of interest.
145. Defendants intended to cause the Plaintiff K Stephens severe emotional distress by
disseminating plaintiffs private medical information about her anxiety condition with
opposing counsel, the court, and the jury.
146. Defendant Vangelisti Kocher intended not to inform the plaintiff that they were going to
disseminate her private medical information and knew that it would cause the plaintiff

grave distress if she were to find out that her private medical information was shared with
opposing counsel, the court and the jury.
147. The Defendants intended to cause the plaintiff severe emotional distress by intentionally
losing the plaintiffs daughter case.
148. Defendants intended to cause the plaintiff severe emotional distress by making sure that
the plaintiffs daughters case was never properly investigated by authorities.
149. Defendants intended to cause the plaintiff severe emotional distress by making sure that
the people who abused and neglected her daughter received no consequences and that the
plaintiffs daughter received no restitution for being the victim of such criminal activity.
150. Defendants intended to cause the Plaintiffs severe emotional distress and an emotional
breakdown by taking the Plaintiffs daughters case to trial.
151. Defendant Lachenmier and Defendant Vangelisti Kocher intended to cause the plaintiff
severe emotional distress by not informing her of the $25,000 offer of judgment which would
have ended the litigation and instead encouraging her to attend her daughters trial which the
defendant Vangelisti Kocher and Defendant Lachenmier knew was certain to fail.
152. Defendant Vangelisti Kocher used its position, as the Plaintiffs attorney, to protect Todd
Burkholder from criminal and civil prosecution because the defendant knew Todd
Burkholders brother who is a prominent Oregon politician.
153. Defendant Vangelisti Kocher used its position, as the plaintiffs attorney, to protect
Aimee McQuiston from criminal and civil prosecution because the defendant knew Aimee
McQuistons brother in-law who is a prominent Oregon politician.
154. Defendants discredited the plaintiff as Qadiras guardian ad litem.

155. Defendant Vangelisti Kocher did not inform the plaintiff or protect the plaintiffs legal
rights as Qadiras guardian ad litem.
156. Defendants did not have the plaintiffs daughters case properly investigated.
157. Defendant Vangelisti Kocher used its position as the plaintiffs attorney to manipulate the
plaintiff into believing that her daughters case was a simple personal injury case; that it was
only an accident; and was only about damages where liability was not at issue.
158. Defendants did not inform the plaintiff that she had an option to prosecute her daughters
case criminally.
159. Defendant Vangelisti Kocher failed to involve testimony or documentation from the ER
doctor or any doctor at trial.
160. Defendant Vangelisti Kocher improperly led defense witnesses through the trial, not
allowing them to tell their version of events.
161. Defendant Vangelisti Kocher failed to file a motion for a judgment notwithstanding the
verdict under ORCP rule 63 after the plaintiff asked him to do so and despite the fact that
McQuiston proffered no evidence of not being negligent.
162. Defendant Vangelisti Kocher failed to submit critical evidence of a phone call in which
McQuiston admitted to Qadira being burned at her house when the Plaintiffs asked him to do
so.
163. Defendants recklessly and negligently failed to advise the plaintiff that her private
medical information was breached in Qadiras medical report. Defendant knew or should
have known that the plaintiff was identified in Qadiras medical report on May 17, 2007 as
suffering from anxiety.

164. Defendants recklessly and negligently disseminated plaintiffs private medical
information about her anxiety condition with opposing counsel, the court, and the jury.
165. Defendants negligently and recklessly failed to advise plaintiff that Qadiras treating
doctors inserted baseless determinations that Qadiras injury was accidental and inserted
unverified and unsubstantiated testimony with no known source into Qadiras medical
records.
166. Defendants recklessly and negligently failed to advise the plaintiff that it was bringing
the testimony of treating doctors via Qadiras medical reports that were adverse to the
plaintiffs daughters claim of negligence.
167. Defendanst failed to inform the plaintiff that Todd Burkholder and Aimee McQuiston had
committed the crime of child abuse and child neglect under Oregon law and that the case
needed to be referred to the authorities for criminal prosecution.
168. Defendants knew or should have known that Dr. Sarah Tubbesing did not interview
Qadira or the plaintiff about any account of events and that the evidence contained in her
report could not have been obtained from the plaintiff or her daughter and should have been
controverted.
169. Defendants knew or should have known that the McQuiston and Burkholder were never
identified to the hospital and therefore not a possible source for Dr. Sarah Tubbesings
testimony.
170. The Defendants knew or should have known that unverified and unsubstantiated evidence
did not belong in Qadiras medical records.
171. Defendants negligently and recklessly failed to advise the plaintiff that any determination
about Qadiras injury before litigation should have been established by the Police or DHS

because her treating doctors were not in contact with all responsible parties and did not have
all the facts.
172. Defendants knew or should have known that tea kettles do not boil themselves to a
scalding level and accidentally walk themselves into bathrooms (where they do not belong)
with naked children present.
173. Defendants recklessly and negligently failed to advise the plaintiff that law enforcement
would be unlikely to investigate after a ruling in a civil trial.
174. Defendants recklessly and negligently disseminated unsubstantiated testimony and
evidence to the opposing counsel, the court, and the jury.
175. Defendants recklessly and negligently failed to inform the plaintiff that it was going to
agree with the court and defense counsel that the circumstances surrounding Plaintiff Q.
Stephens injury were not to be considered. Specifically, the fact that McQuiston had a teapot
full of scalding water in the bathroom; the fact that the plaintiffs daughter was involved in
an adult supervised naked game; the fact that Todd Burkholder walked into the bathroom
which contributed to the plaintiffs daughters injury; and the fact that the plaintiffs daughter
suffered for an undisclosed amount of time in the Burkholder basement without medical
attention.
176. Defendant Vangelisti Kocher knew or should have known since it submitted the
unverified report and baseless determination of Dr. Sarah Tubbesing as part of plaintiffs
daughters official medical report that the jury would believe that Qadiras injury was
accidental and therefore find no liability of McQuiston.

177. Defendant Vangelisti Kocher knew or should have known that no reasonable juror would
have made a determination against the report and determination of a medical doctor,
especially if they did not know that the report was unverified.
178. Defendant Vangelisti Kocher recklessly and negligently advised the plaintiff go to trial
without verbal testimony or attendance of its client Qadira, its key witness for the action, and
did not explain the risks of doing so to the plaintiff.
179. Defendant Vangelisti Kocher knew or should have known that defendant should have
advised the plaintiff that not bringing Qadira to testify at trial could also be detrimental to
Qadiras case. Defendant denied the plaintiff the opportunity to decide whether to settle or
take Qadiras case to trial based on that information.
180. Defendant Vangelisti Kocher recklessly and negligently advised John Barker, the
mediator, but failed to advise the plaintiff that it believed that a jury would not punish
McQuiston.
181. Defendant Vangelisti Kocher knew or should have known that failure to advise the
plaintiff of this assessment would deny her the opportunity to question why the defendant
believed that a jury would be unlikely to punish Mrs. McQuiston. This failure denied the
plaintiff the opportunity to settle or seek an assessment from other counsel.
182. Defendant Vangelisti Kocher knew or should have known that it should have informed
the plaintiff of the offer and advised the plaintiff to take the offer because plaintiff had
expressed her strong desire not to put Qadira through a trial, which was a change in the
circumstances that defendant presented at mediation; and because defendant intended to
include Dr. Sarah Tubbesings baseless determination and unsubstantiated report incident,
unchallenged without informing the Plaintiffs

183. Defendant Vangelisti Kocher was responsible for recommending the plaintiff to be
Qadiras guardian ad litem to the court. Defendant was representing plaintiff in her role as
guardian ad litem and failed to advise her that she needed training to be Qadiras guardian ad
litem, or that she needed to be a trained CASA or attorney because federal law requires this
in cases of child neglect that lead to any judicial proceeding.
184. Defendants negligently and recklessly petitioned to have the plaintiff appointed
regardless of her lack of qualifications. Defendant did not present plaintiff with any other
options, except that the court required a guardian ad litem and that the plaintiff needed to
serve in that role.
185. Defendants knew or should have known that the plaintiff should not have been appointed
Qadiras guardian ad litem based on the plaintiffs lack of qualifications; the plaintiffs
existing medical condition of anxiety; and the plaintiffs extraordinary life stressors which
included dealing with Qadiras burn injury, dealing with the death of her father in-law,
dealing with the circumstances surrounding the loss of the family income, dealing with the
loss of the family income, dealing with her youngest daughters illnesses including
pneumonia and Kawasakis syndrome (which is a life threatening illness from which she
almost died), and holding down a job as a caregiver in an adult foster care home on weekends
to help support her family, which defendant was aware of.
186. Defendants knew or should have known that by placing the extra burden and
responsibility of serving as Qadiras guardian ad litem onto the plaintiff that it was
substantially certain to cause the plaintiff severe emotional distress because of plaintiffs
anxiety condition.

187. Defendant knew or should have known that when the plaintiff was appointed guardian ad
litem for Qadira that the plaintiff would be responsible for making sure that Qadiras claim
was handled properly.
188. The Defendants knew or should have known that the plaintiff would fail as guardian ad
litem for Qadira because of her lack of qualifications. Defendant was aware that the plaintiff
was distressed about Qadiras injury and was substantially certain, based on the plaintiffs
existing anxiety condition and compound extraordinary life stressors, that if the plaintiff
failed in her role as Qadiras guardian ad litem it would cause her grave distress.
189. Defendants knew or should have known based on plaintiff K Stephens existing anxiety
condition that if the plaintiff discovered information about Qadiras case that was not
presented to her before the trial that it would cause her grave distress.
190. Defendant Vangelisti Kocher recklessly and negligently failed to advise the plaintiff that
Scott F. Kocher personally knew Rex Burkholder (a prominent Oregon politician and
brother-in-law to McQuiston) and served on a committee with him from approximately 1990-
1992. Defendant Vangelisti Kocher knew or should have known that because of the
circumstances surrounding Qadiras burn injury that the plaintiff would have been
uncomfortable with that association and would have wanted to seek other counsel based on
that information. Defendant knew or should have known that this would be an issue after
Rex Burkholders name was mentioned in McQuistons deposition. Defendant knew or
should have known that if the Plaintiffs discovered this information after Qadira lost her trial
it would cause them severe emotional distress.
191. Defendant Nike was upset that Plaintiff R. Stephens complained to the EEOC and
showed the EEOC the letter stating that there was behavior inconsistent with Nike policy.

Defendant Nike felt they had handled the situation appropriately and Plaintiff R. Stephens
had no right to complain to the EEOC.
192. Defendant Nike was upset when plaintiff R Stephens asked for them to move him or to
move Randy Wolfe because Defendant Nike did not feel that plaintiff R Stephens had any
right to ask for anything because plaintiff R Stephens is not white, wealthy, or related to
anyone of importance.
193. Defendant Nike felt as if they had done plaintiff R Stephens a favor for letting him work
up at Nike for eight years. Defendant Nike employs very few people of color at their
company and most Nike employees are white, upper middle class and with the exception of
the many workers who are employed overseas making the product, Defendant Nike does not
usually hire individuals who are not white, wealthy, or related to anyone of importance.
194. Defendant Nike decided that they were going to terminate Plaintiff R. Stephens while
Plaintiff R. Stephens was attending his fathers funeral. Defendant Nike asked Plaintiff R.
Stephens to work with Shawn Wenzel after he returned from his fathers funeral on April 2nd
to get plaintiff R. Stephens to believe that he was part of the NASCAR initiative.
195. On the night of April 12
th
2007 after Plaintiff Q Stephens was burned at the home of
Defendant McQuiston and Defendant Todd Burkholder, Defendant Todd Burkholder came to
the Stephens home not to help Plaintiff K and R Stephens but to find out where Plaintiff K
and R Stephens were taking Plaintiff Q Stephens so that Defendant Burkholder could get his
brother Rex Burkholder to downplay the situation so that Portland Police and DHS would not
be notified.

196. Defendant Todd Burkholder contacted his brother Defendant Rex Burkholder so that he
could use his influence as a SW City Councilor to protect Defendants T. Burkholder and
McQuiston from criminal prosecution.
197. Defendant Todd Burkholder and Defendant McQuiston were facing serious charges and
prison time for the crimes that they perpetrated against Plaintiff Q Stephens. Defendant
Todd Burkholder and Defendant McQuiston downplayed the severity of Plaintiff Q Stephens
injury by telling Plaintiffs K and R Stephens that Plaintiff Q Stephens wanted to come
home.
198. Defendant Todd Burkholder insisted that Plaintiff K and R Stephens did not need to take
Plaintiff Q Stephens to the hospital and suggested they just put Aloe Vera on Plaintiff Q
Stephens burn. Defendant Todd Burkholder and Defendant McQuiston did not want Plaintiff
Q Stephens to be seen at any hospital because they did not want anyone asking questions
about what they were doing on the night of April 12 2007.
199. Defendant Todd Burkholder started a malicious rumor that Plaintiff K and R Stephens
were out for money and unconcerned about their daughter to distract all involved parties
from what defendant Burkholder and Defendant McQuiston had been doing on the night of
April12th 2007.
200. Defendant Rex Burkholder began repeating this malicious rumor because he believed his
brother and wanted to protect him from criminal prosecution and because the Stephens are
not white, wealthy, and unrelated to anyone of importance Defendant Rex Burkholder never
questioned the validity of his brothers statement.
201. Defendant Rex Burkholder, Defendant McQuiston, and Defendant Todd Burkholder all
downplayed the events surrounding the injury of plaintiff Q. Stephens and Defendant Rex

Burkholder used his credibility as a SW City Councilor to add merit to Defendant Todd
Burkholder and Defendant McQuiston assertions that what happened to Qadira was just an
accident.
202. Defendant Rex Burkholder contacted Providence hospital and told them not to report
Plaintiff Q Stephens injury, that it was just an accident, and that he would take care of it.
203. On the night of April 12
th
2007Plaintiff K and R Stephens were in severe shock after
Plaintiff Q Stephens was burned and had stayed up most of the night tending to their
daughter after being sent home by Defendant Julie Andrews with Plaintiff Q Stephens.
Plaintiff R Stephens contacted Defendant Burkholder/McQuiston early on the morning of
April 13
th
2007 to ask for their homeowners insurance because Plaintiff K Stephens was
going to take Plaintiff Q Stephens to OHSU to have her burn further evaluated and her
bandages changed.
204. Defendant Rex Burkholder contacted defendant Joe Robertson and asked him to
downplay what happened to Plaintiff Q Stephens, to not transfer her to the burn unit, that this
was just an accident and that based on the fact the Stephens had asked for homeowners
insurance that the Stephens were just out for money anyway. Defendant Rex Burkholder did
not believe that his brother Defendant Todd Burkholder and Defendant McQuiston should
have to face any prosecution for injuring Plaintiff Q Stephens because Plaintiff Q Stephens is
not white, wealthy, or related to anyone of importance.
205. Defendant OHSU and Defendant Providence knew that Plaintiff Q Stephens burn could
possibly cause her severe internal distress including sepsis, shock, organ failure and death but
failed to treat Plaintiff Q Stephens burn injury because they were more concerned about
protecting Defendants Todd Burkholder and Aimee McQuiston from going to jail and doing

a favor for Rex Burkholder than for the life of Plaintiff Q Stephens. Defendant Joe
Robertson now believed the rumor started by Defendant Todd Burkholder because Defendant
Rex Burkholder had repeated it and he is a reputable politician in Oregon. Defendant Joe
Robertson took Defendant Rex Burkholder on his word. Defendants knew that if Plaintiff Q.
Stephens was admitted to any hospital (especially the Oregon Burn Center) that Defendants
would not be able to hide the severity of Plaintiff Q. Stephens injury.
206. Defendant Todd Burkholder told Defendant State Farm insurance company and
Defendant Portland Public Schools that Plaintiff R. Stephens and Plaintiff K. Stephens asked
for his homeowners insurance because they were just interested in getting money and that
based on that they did not care about Plaintiff Q. Stephens. Defendant State Farm and
Defendant Portland Public Schools believed this rumor as fact because Defendant Todd
Burkholder is the brother of Defendant Rex Burkholder and because Rex Burkholder is
white, a prominent politician, powerful, and upper middle class and the Plaintiffs are not.
Defendants Todd Burkholder and Defendant Rex Burkholder began spreading this malicious
rumor about Plaintiff K and R Stephens to distract people from the crime Defendant
McQuiston and Defendant Burkholder had committed.
207. Defendant OHSU and Defendant Providence inserted a baseless version of events into
plaintiff Q. Stephens medical record in order to make it appear as though there had been an
official investigation into the circumstances surrounding Plaintiff Q. Stephens injury and in
order to definitively protect Defendants Todd Burkholder and Aimee McQuiston from
criminal prosecution.
208. Defendant State Farm, defendant OHSU, and defendant Providence believed
Burkholders assertions about the Stephens family and wanted to punish K and R Stephens

because Rex Burkholder is white and a prominent politician and the Stephens are not white
and not related to anyone of importance.
209. Defendant OHSU and Defendant Providence made no effort at any time to get an expert
opinion on the actual severity of the burn that Plaintiff Q. Stephens sustained because
defendant OHSU and defendant Providence did not want to know the actual severity of
Plaintiff Q Stephens injury because the defendants wanted to prevent her transfer to the
Oregon Burn Unit and prevent any police involvement at all in order to protect Todd
Burkholder and Aimee McQuiston.
210. Defendants OHSU and Defendant Providence did not take any vitals, blood work, or do
any further physical examination on Plaintiff Q Stephens because they did not want
documentation of Plaintiff Q Stephens true physical state after she was burned to exist
making it easier for Defendants McQuiston, Burkholder, OHSU and Providence to hide the
circumstances surrounding Plaintiff Q Stephens burn, and to deny any liability if their failure
to treat resulted in further illness or the death of Plaintiff Q Stephens.
211. Defendant OHSU sent plaintiff R. Stephens and Plaintiff K. Stephens home to care for
Plaintiff Q. Stephens injury alone and without any medical supervision in an effort to inflict
severe and debilitating psychological and emotional distress on to the entire Stephens family
so they would have no time to process what had occurred and to avoid drawing additional
attention to plaintiff Q. Stephens injury.
212. Defendant OHSU and Defendant Providence knew or should have known that burns of
the size and nature sustained by the Plaintiff Q. Stephens needed immediate specialized care
and that sending her home to be cared for by her unqualified parents was putting her at risk
for serious bodily harm including sepsis, shock, organ failure, and death.

213. Defendant Providence and Defendant OHSU did not refer Plaintiff Q. Stephens for
proper medical treatment at the Oregon Burn Center or treat her burn because Defendant Rex
Burkholder asked them not to and because Plaintiff Q. Stephens is not white, not wealthy and
not related to anyone of importance Defendant Providence and Defendant OHSU were
unconcerned for her health and welfare and were more concerned that Defendant T.
Burkholder and McQuiston would be prosecuted for what they had done.
214. Defendant Nancy Gorden Zwerling who was Qadiras primary care physician until May
2011 hid all of Qadiras medical conditions from her parents, agreeing to keep her condition
a secret as a favor for Defendant OHSU, Defendant Knight, Defendant Nike, Defendant
Lachenmier, Defendant Vangelisti Kocher and other Defendants that may have been
informed of Plaintiff Q Stephens condition.
215. Defendant Portland Public Schools returned Plaintiff Q. Stephens to the Odyssey
program while allowing Defendants Todd Burkholder and Aimee McQuistion to continue to
volunteer in an effort to inflict severe emotional and psychological damage onto Plaintiff Q.
Stephens after she was burned by forcing her to have direct contact with her abusers.
216. In July 2007 the EEOC contacted Plaintiff R. Stephens and asked him if he would be
interested in dropping his charge against Defendant Nike because the EEOC wanted plaintiff
R Stephens to drop his charge without investigation because Nike was guilty. Defendant
Nike had just been penalized for discrimination in their Chicago store and had just signed a
consent decree with the EEOC and any further charges of discrimination would not be good
for Defendant Nikes image. Defendant Nike told the EEOC that Plaintiff R Stephens was
just money hungry and trying to use his daughter to get money from an accident to
persuade the EEOC to dismiss Plaintiff R Stephens complaint.

217. Defendant Federal investigator Matthew Cleman believed the assertions of Defendant
Nike and Defendant Burkholder and continued not to take any action on behalf of Plaintiff R
Stephens to punish Plaintiff R Stephens as a favor For Nike.
218. On August 13
th
Claire Hamill contacted Plaintiff R. Stephens via email and asked him to
convene in her office for a quick touch base. Plaintiff R Stephens was told that he needed
to find another job, Hamill, Brunke, and McDevitt intended to cause Plaintiff R. Stephens
severe emotional distress and snickered and laughed at him during the meeting. Defendant
Nike knew that Plaintiff R. Stephens father had died and his daughter had been burned and
that the school year was about to begin so Defendant Nike felt that is was an optimal time to
inflict the highest level of emotional distress onto Plaintiff R. Stephens. Because Plaintiff R
Stephens was already experiencing extraordinary life stressors it was a possibility that the
loss of Plaintiff R Stephens job on top of everything else would drive Plaintiff R Stephens
over the edge which would mean that he was no longer a problem for Defendant Nike.
Defendant Nike had heard the rumor that Plaintiff R Stephens was just money hungry and
intended to crush Plaintiff R and K Stephens especially because they were not white,
wealthy, or related to anyone of importance.
219. After Plaintiff R Stephens was laid off he contacted Defendant EEOC and filed a charge
of retaliation because he felt that he was being laid off in retaliation for having filed his
initial charge of discrimination and because he was being fired while he had an open EEOC
charge pending.
220. Defendant Nike was upset because Plaintiff R Stephens filed a charge of retaliation
against them in August 2007 and offered him a severance package contingent on a release of
claims to get rid of him once and for all. Defendant Nike believed Plaintiff R. Stephens had

no choice but to accept the severance package because Plaintiff R. Stephens is not white, not
wealthy, unrelated to anyone of importance and had many responsibilities including a wife
and four small children to provide for. Defendant Nike made sure that Plaintiff R. Stephens
had no re-employment opportunities to help ensure that he would sign the release of claims
which would have absolved Defendant Nike from both pending EEOC charges.
221. Defendant Nike announced a strategic review of its Exeter Brands Group, LLC in
September 2007 while they waited to see if Plaintiff R. Stephens would sign the severance
agreement therefore absolving them of the pending EEOC charges. Defendant Nike had no
intention of selling Starter and shutting down Exeter Brands Group LLC which was a
growing and lucrative business within the company. Defendant Nike had just signed a multi-
year contract with Payless Shoe Source to exclusively market the new Tailwind product and
the Starter product was doing very well in Wal-Mart. Exeter Brands Group LLC was doing
very well in the spring of 2007 when Plaintiff R Stephens complained. Defendant Nike
figured that after Plaintiff R Stephens signed the severance agreement they would be able to
go back to business as usual.
222. Defendant Nike was upset when plaintiff R. Stephens declined to accept and sign the
severance agreement because they were guilty of discrimination/retaliation against Plaintiff
R. Stephens and by laying him off Defendant Nike had made the whole situation worse.
223. Defendant Nike had already lied to the EEOC and to Plaintiff R Stephens that Plaintiff R.
Stephens was laid off due to the fact that all NASCAR positions were eliminated and
Defendant Nike were upset when Plaintiff R. Stephens pointed out this fact to Federal
investigator Matthew Cleman. Defendant Nike was faced with shutting down an entire
business unit, Exeter Brands LLC in order to rid themselves of Plaintiff R Stephens EEOC

charges and Plaintiff R Stephens once and for all. Defendant Nike was determined that
Plaintiff R Stephens would never work in the footwear industry again because they believed
the lies and rumors being perpetrated by Defendant Rex Burkholder and because they were
angry at Plaintiff R Stephens for filing EEOC charges against them.
224. Defendant Nike wanted to punish Plaintiff R. Stephens for causing so much trouble by
complaining. Defendant Nike felt that the events that had transpired were the fault of
Plaintiff R. Stephens and since Defendant Nike now had it on good authority from Defendant
Rex Burkholder and Defendant Joe Robertson that Plaintiff R Stephens was just money
hungry Defendant Nike decided to use Plaintiff Q Stephens burn injury case against
Plaintiff K and R Stephens.
225. On November 17
th
after Plaintiff R. Stephens filed his 3
rd
charge of discrimination based
on defamation, Defendant Nike contacted Vangelisti Kocher, LLP and asked them to file suit
against Defendant McQuiston to publicly make Plaintiff R. Stephens and Plaintiff K.
Stephens appear money hungry and unconcerned about their daughter. Defendant
Vangelisti Kocher never had any intention of ever prosecuting Plaintiff Q Stephens case.
Defendant Vangelisti Kocher made Plaintiff K Stephens Plaintiff Q Stephens Guardian ad
litem to make it appear that she was the one who had filed the lawsuit against McQuiston.
Defendant Nike needed definitive proof show to EEOC investigator Matthew Cleman that
the Stephens were money hungry so that he would absolve Defendant Nike of all of the
charges filed by Plaintiff R. Stephens.
226. Defendant EEOC believed Defendant Nikes story about Plaintiff R. Stephens and
intended to help Defendant Nike inflict severe emotional distress on Plaintiff R. Stephens by

ignoring all of the evidence presented by Plaintiff R. Stephens and dismissing all of Plaintiff
R. Stephens complaints with indeterminate findings.
227. On January 22, 2008 Defendant OHSU became aware that Plaintiff Q. Stephens was very
sick and exhibiting clear signs of internal distress in the form of sepsis, liver damage, low
white blood cell count etc. But did not inform Plaintiff K. Stephens and Plaintiff R. Stephens
because they did not want Plaintiff K. and R. Stephens to connect Plaintiff Q. Stephens
internal damage to their response and failure to treat plaintiff Q. Stephens burn injury.
Defendant OHSU informed Defendant Lachenmeier and Defendant Vangelisti Kocher of
Plaintiff Q Stephens condition and asked them to ask Plaintiff K and Q Stephens about the
wound care that Defendant OHSU had ordered Plaintiff K and R Stephens to administer.
Defendants intended to cause Plaintiff K and R Stephens severe emotional distress with the
death of plaintiff Q Stephens.
228. Defendant Kocher and Defendant Lachenmeier deposed Plaintiff K. Stephens, Plaintiff
Q. Stephens, Defendant T. Burkholder, Defendant McQuiston, and Sophie Burkholder to try
to dig up adverse information about Plaintiffs K. and R. Stephens. Because Plaintiff Q
Stephens was now seriously ill and possibly dying Defendant Joe Robertson wanted to see if
they could dig up any information that could implicate Plaintiff K and R Stephens in the
internal injuries now being suffered by Plaintiff Q Stephens. Defendant Lachenmeier
specifically questioned Plaintiff K and Q Stephens about the wound care that Plaintiff K and
R Stephens had administered. Plaintiff K and R Stephens had only done what Defendant
OHSU had told them to do but because they were not burn experts or medical professionals
in any capacity and had absolutely no idea what they were doing or what they were looking
at the entire time they had cared for Plaintiff Q Stephens at home all alone there was very

little Plaintiff K and Q Stephens could tell Defendant Lachenmeier and Defendant Kocher
about Plaintiff Q Stephens burn injury.
229. Defendant Lachenmeier, Defendant Kocher, and Defendant Joe Robertson, along with all
of Plaintiff Q Stephens treating doctors agreed to keep Plaintiff Q Stephens health condition
a secret from Plaintiff K and R Stephens. The Defendants had no information to suggest that
Plaintiff K and R Stephens had done anything wrong and their own inaction on the night of
April12th 2007 and in the ensuing months had produced the situation they were now all
faced with which was bad.
230. Defendant Nike and Defendant Phil Knight were furious at Plaintiff R. Stephens because
Plaintiff R. Stephens was contacting multiple law firms about his EEOC charges and
potential case against Nike. Defendant Mitra Shari took Plaintiff R. Stephens case so he
would stop talking to attorneys about his case. Defendant Shari intended to protect
Defendant Nike and intended to cause Plaintiff R. Stephens severe emotional distress and run
out Plaintiff R Stephens statute of limitations so he could no longer file suit against
Defendant Nike. Defendant Shari declined to file Plaintiff R Stephens case just 10 days
before his statute of limitations ran out to cause Plaintiff R Stephens severe emotional
distress and to help Defendant Nike.
231. Defendant Rex Burkholder and Defendant Joe Robertson wanted to settle plaintiff Q
Stephens case in the summer of 2008. Defendants had gotten away with covering up the
child abuse perpetrated against Plaintiff Q. Stephens and Defendant Rex Burkholder and
Defendant Joe Robertson had accomplished their goal of protecting Defendant Todd
Burkholder and Defendant McQuiston from criminal prosecution. Defendant Rex
Burkholder and Defendant Joe Robertson wanted to wash their hands of the entire matter

because they knew that Plaintiff Q. Stephens was in internal distress and could have a
medical emergency at any time. Defendant Rex Burkholder and Defendant Joe Robertson
wanted to distance Plaintiff Q. Stephens burn injury from any medical distress that Plaintiff
Q. Stephens was to experience in the near future as a result of her untreated burn injury.
232. Defendant Nike was furious when Plaintiff R. Stephens filed his pro se complaint in June
of 2008 because of the nature of the complaint and because Defendant Nike was guilty of all
of Plaintiff R Stephens allegations. Defendant Nike hired Stoel Rives as counsel to
intimidate and harass Plaintiff R Stephens. Defendant Nike convinced Defendant Vangelisti
Kocher LLP , Defendant Joe Robertson, Defendant Rex Burkholder and Defendant
Lachenmeier to not settle Plaintiff Q Stephens case but instead to take her case to a trial
where the Defendants would bring Plaintiff K Stephens and Plaintiff R Stephens to inflict
severe and debilitating emotional distress on them by psychologically and verbally attacking
in front of a jury of their peers, making them appear as though they were maliciously going
after McQuiston, and by denying them any ability to understand the circumstances
surrounding Plaintiff Q Stephens injury.
233. Defendant Lachenmeier deposed Plaintiff R Stephens to investigate him for defendant
Nike and to attempt to dig up information that could be used against him and Plaintiff K and
R Stephens at the trial to cause them both severe and debilitating emotional and
psychological distress.
234. Defendant Lachenmeier filed the $25,000 offer of judgment, signed by Defendant
McQuiston, and defendant Vangelisti Kocher filed Plaintiff Q. Stephens falsified OHSU
medical records, stating that Plaintiff Q. Stephens burn injury was an accident, to make the
court and the public believe that Plaintiff Q. Stephens burn injury was just an accident,

that had been properly investigated and treated appropriately at OHSU hospital and that
Plaintiff K. Stephens was blowing it out of proportion because she had anxiety, and that
Defendant State Farm had offered a reasonable amount of money to settle the claim and that
Plaintiff K and R Stephens had declined the offer because they were money hungry and
that Plaintiffs K. and R. Stephens were maliciously prosecuting Defendants T. Burkholder
and McQuiston.
235. Defendants Vangelisti Kocher, Defendant Lachenmeier, Defendant Nike and Defendant
Robertson informed Defendant McShane that Plaintiff K and R Stephens were just money
hungry and unconcerned for their daughter. Defendant McShane believed the story
because it was coming from reputable people and agreed to preside over the trial and to help
all involved Defendants cause Plaintiff K and R Stephens severe emotional distress because
Defendant McShane wanted to help punish K and R Stephens for Defendant Nike and all
involved parties.
236. Defendant Nike, Defendant Joe Robertson and Defendant Rex Burkholder intended to
use Plaintiff Q Stephens burn injury case through Vangelisti Kocher, LLP; Defendant
Kocher; Defendant Vangelisti; and Defendant Lachenmeier to cause Plaintiff K and R
Stephens severe and debilitating emotional distress so that Plaintiff R Stephens would stop
prosecuting his lawsuit against Defendant Nike and so that Defendant OHSU, and Defendant
Providence, Defendant Lachenmeier, Defendant Joe Robertson, Defendant Rex and Todd
Burkholder, Defendant McQuiston and Defendant Vangelisti Kocher would be protected
from all liability in regards to their failure to treat Plaintiff Q Stephens burn injury or report it
to the proper authorities and definitively protected from criminal prosecution for covering up
a crime.

237. Plaintiff K Stephens and Plaintiff R Stephens were subjected to intense emotional and
psychological harm at the trial of Plaintiff Q. Stephens where Defendants McShane,
Lachenmeier, and Kocher attacked both plaintiffs K and R Stephens on the stand, making
fun of their childrens names, insinuating they had further harmed their daughter on the night
of April 12
th
2007, making fun of Plaintiff R Stephens position as a welder and making sure
the jury knew and understood that Plaintiff R Stephens used to work at Nike but was no
longer employed in his industry insinuating he had been fired for cause, insinuating that
Plaintiff K and R Stephens were always feuding with their neighbors, that they didnt bring
any psychologists, doctors, witnesses or even Plaintiff Q Stephens because Plaintiffs K and
R Stephens were really just out for money.
238. Defendant Portland Public Schools allowed the use of Odyssey Program materials to
make it appear as those the girls were playing a game called Little house on the prairie.
Portland Public Schools also wanted to help inflict severe emotional distress onto Plaintiff K
and R Stephens for suing McQuiston and Burkholder and for suing Nike.
239. Defendants downplayed the severity of Plaintiff Q Stephens injury and did not inform
the jury that there had never been an actual investigation into the circumstances surrounding
Plaintiff Q Stephens injury or that the hospitals failed to report or treat Plaintiff Q Stephens
injury. Defendant Susan Glosser led the jury behind closed doors to ensure they delivered a
defense verdict for McQuiston and did not get caught up in the particulars of the trial. The
Defendants conducted the trial with the intention that it would completely destabilize
Plaintiff K and R Stephens and cause them to harm themselves, or someone else. Defendants
intended to cause Plaintiff K and R Stephens to commit a crime or commit suicide so that all
involved parties could wash their hands of the entire situation.

240. Defendants did not get the desired response from Plaintiffs K and R Stephens.
Defendants were upset when Plaintiff K and R Stephens began filing complaints and
attempting to contact officials with news of what had occurred.
241. Defendants told everyone who would listen that Plaintiff K and R Stephens were just
money hungry in order to deflect attention from the real crime. Plaintiffs K and R
Stephens never had a snowballs chance in hell of ever getting an investigation into Plaintiff
Q Stephens injury because they are not white, wealthy, or related to anyone of importance.
242. Defendant Portland Police Bureau declined to investigate Plaintiff Q Stephens burn
injury, the circumstances surrounding Q Stephens injury and trial to protect all involved
parties who had so diligently sought to cause Plaintiff K and R Stephens severe emotional
distress because the Portland Police Bureau believed that Plaintiff K and R Stephens were
just money hungry and they wanted to protect Nike and all involved parties from any
investigation.
243. Defendant Portland Police Bureau refused to investigate because Plaintiff Q Stephens
was a victim of child abuse and all involved parties who had failed to report her injury, who
had failed to treat her injury and who had sought to exploit Plaintiff Q Stephens burn injury
case were now looking at federal charges of conspiracy to cover up a crime. The Portland
Police Bureau believed Rex Burkholders assertions about the Stephens family because the
Stephens family is not white, wealthy, or related to anyone of importance and they wanted to
protect their friends. Defendant Portland Police Bureau wanted to protect all involved
Defendants because they believed that Plaintiff Q Stephens was not worth convicting all of
the involved Defendants.

244. Defendant DHS visited Plaintiff Q Stephens but were told by Defendant Lachenmeier
that the Plaintiff K and R Stephens were angry and money hungry and that a civil trial
had produced a no negligence finding in favor of Defendant McQuiston. Defendant DHS
closed Plaintiff Q Stephens case as unable to determine because they believed Defendant
Lachenmeiers assertions about Plaintiff K and R Stephens because they were being backed
up by very powerful people and Defendant DHS now wanted to help all involved parties
inflict severe emotional distress onto Plaintiff K and R Stephens for being money hungry
and suing Nike. Defendant DHS took Rex Burkholder, Defendant Nike, Defendant
Vangelisti Kocher and Defendant Joe Robertsons word that what had happened to Plaintiff
Q Stephens was just an accident because Defendants are white, wealthy and powerful and
Plaintiffs K, Q, and R Stephens are not.
245. Defendant Portland Police Bureau denied Plaintiff K Stephens, Plaintiff R Stephens and
Plaintiff Q Stephens equal protection under the law because the Stephens are not white,
wealthy, or related to anyone of importance and because the bureau believed that the
Stephens were money hungry as so asserted by defendant Rex Burkholder, Defendant
Lachenmeier, Defendant Vangelisti Kocher and Defendant McShane and Defendant Nike.
Defendant Portland Police Bureau ignored the fact that Plaintiff Q Stephens had been
subjected to abuse and neglect and ignored the fact that Plaintiff K and R Stephens had
reported plaintiff Q Stephens injury to many mandatory reporters. Portland Police Bureau
discriminated and continues to discriminate against the Stephens family because they are not
white, wealthy or related to anyone of importance.
246. Defendant McShane denied plaintiff Q Stephens motion for a new trial because he
believed that the Stephens had only sued McQuiston because they were money hungry and

he was angry at K and R Stephens because R Stephens had sued Nike. Defendant McShane
was very angry at Plaintiff K Stephens for even attempting to further pursue Plaintiff Q
Stephens case because it could mean trouble for a whole lot of powerful people.
247. Defendant Oregon State Bar believed the story that the Stephens were just money
hungry and sought to help inflict severe emotional distress onto Plaintiff K and R Stephens
by dismissing all complaints against Defendant Vangelisti Kocher without addressing any of
the issues Plaintiff K Stephens presented to them.
248. On October 29
th
2008 faced with the uncertainty of the impending lawsuit brought by
Plaintiff R Stephens and with the assurance from the Portland Police Bureau that Plaintiff Q
Stephens burn injury and the circumstances surrounding the burn injury would never be
investigated Phil Knight personally gave Joe Robertson and OHSU 100 million dollars in
exchange for OHSUs continued agreement to continue to not treat Plaintiff Q Stephens and
to let her die when the infection and internal distress finally overcame her tiny body.
249. Defendant Knight was angry at Plaintiff R Stephens because Defendant Nike was
forced to pretend to shut down an entire subsidiary, Exeter Brands Group LLC in order to
dodge the charges from the EEOC and the impending lawsuit in Washington County Court.
Plaintiff K and R Stephens had made it through the trial which should have pushed them
completely over the edge and caused them to go crazy and Defendant Nike was now faced
with trying to explain away Plaintiff R Stephens complaint. Defendant Nike explained away
their behavior to all involved judges by pointing out that Plaintiff R Stephens was a bad
person who was money hungry who had harmed his daughter and tried to exploit her and
Nike. Defendant Phil Knight felt that Plaintiff R Stephens deserved to suffer the loss of
Plaintiff Q Stephens because Defendant Knight was angry at Plaintiff R Stephens because he

had to pretend to shut down Exeter brands group and this was causing a lot of problems for
Defendant Nike. Defendant Robertson agreed because no one really had to harm Plaintiff Q
Stephens but just had to continue to not treat the infection that was sure to lead to organ
failure and death. Defendants convinced themselves that it was okay to continue to not treat
Plaintiff Q Stephens because the Defendants had convinced themselves that it was Plaintiff K
and R Stephens that had caused Plaintiff Q Stephens infection in the first place, instead of
their own failure to treat.
250. Defendant Scott Kocher and Defendant Lachenmeier encouraged Plaintiff K Stephens
verbally and in email communications to spend time with Plaintiff Q Stephens because they
knew that Plaintiff Q Stephens was seriously ill and was going to die from OHSUs failure to
treat her infection.
251. Defendant Simrin took Plaintiff Q Stephens appeal as a favor to Nike to help further
destabilize Plaintiff K and R Stephens.
252. In May 2011 DHS refused to reopen Plaintiff Q Stephens in order to protect all involved
Defendants. Defendant DHS intended to inflict severe psychological and emotional distress
on the entire Stephens family by refusing to reopen Plaintiff Q Stephens case. Plaintiff R
Stephens contacted Cares Northwest to ask them to interview Plaintiff Q Stephens and make
a determination as to what had happened to Plaintiff Q Stephens but Cares Northwest
declined to even interview Plaintiff Q Stephens to further distress plaintiff K and R Stephens.
253. On May 25
th
2011 Plaintiff K Stephens discovered the baseless information that had been
inserted into Plaintiff Q Stephens medical report and contacted Defendant Providence and
Defendant OHSU seeking an explanation. Defendant OHSU and Defendant Providence

offered no explanation for their treatment of Plaintiff Q Stephens and Plaintiff K Stephens
stopped trusting them as care providers for plaintiff Q Stephens.
254. In the summer of 2011 Defendant Oregon Emergency Physicians, Defendant Providence
Hospital, and Defendant Oregon Health and Sciences University adamantly refused to
remove the unsubstantiated information from Plaintiff Q Stephens medical records in order to
protect all involved parties because Plaintiff Q Stephens is not white, wealthy, or related to
anyone with importance and to protect all involved parties who have sought to cover up what
happened to Plaintiff Q Stephens
255. On July 5
th
2011 Plaintiff Q Stephens was rushed to Emanuel Hospital near death with a
full blown case of ketoacidosis. Plaintiff K and R Stephens no longer trusted OHSU or
Providence hospital with their children and took Plaintiff Q Stephens to Emmanuel hospital
when she became deathly ill on July 5
th
2011. Emanuel hospital saved the life of Plaintiff Q
Stephens diagnosing her condition as Type 1 Diabetes and pulling in a complete team of
doctors who saved her life.
256. Plaintiffs K and R Stephens have diligently continued to request that the burn injury and
the circumstances surrounding plaintiff Q Stephens burn be investigated. Plaintiff K
Stephens has contacted every available agency that she can think off and contacted many
reputable State and Local officials and media outlets who have all refused to help Plaintiff K
Stephens, Plaintiff R Stephens, and 13 year old Plaintiff Q Stephens.
257. Defendant Stoel Rives and all the Defendant judges involved in Plaintiff R Stephens case
against Nike believed the rumor started by Defendant Rex Burkholder and Defendant Todd
Burkholder as told to them by Defendant Nike and sought to inflict severe and debilitating
psychological distress onto Plaintiff R Stephens and his family. Despite the fact that there

was plenty of evidence and testimony to support Plaintiff R Stephens allegations against
Defendant Nike, the Defendant judges disregarded the evidence in an effort to help
Defendant Nike punish Plaintiff R Stephens for being money hungry and attempting to
exploit his daughter and sue Defendant Nike. Defendant Nike is a billion dollar corporation
and Plaintiff R Stephens case against Nike never had any chance of success because Nike has
so much money they dont have to abide by the law.
258. Defendant Callahan and all of the Defendant Judges involved in Plaintiff K Stephens case
against Vangelisti Kocher believed all of the lies perpetrated about K and R Stephens and
despite the fact that a crime was committed and the life of an innocent child put at risk
Defendants chose to help cover up the crime because Plaintiff Q. Stephens is not white,
wealthy, or related to anyone of importance. It is a miracle that Plaintiff Q. Stephens is alive.
259. Defendant Andrews failed to treat Plaintiff Q. Stephens for her burn injury by not
transferring her to the Oregon Burn Center and by failing to administer basic trauma care.
Defendant Andrews knew or should have known that children diagnosed with severe burn
injuries (i.e., partial thickness burns greater than 10% total body surface area (TBSA); burns
that involve the face, hands, feet, genitalia, perineum, or major joints; and/or burned children
in hospitals without qualified personnel or equipment for the care of children) should be
transferred immediately to the nearest specialized burn treatment facility, as recommended
by the American Burn Association.
260. Defendant Andrews failed to report Plaintiff Q. Stephens burn injury to the
proper authorities (i.e. DHS or the Portland Police) which is required by state and federal
child abuse laws.

261. Defendant Andrews inserted unverified, baseless, and uninvestigated information into
Plaintiff Q. Stephens medical record.
262. Defendant OHSU intentionally caused Plaintiff Karellen and Renee severe
emotional distress by sending them home to directly care for Q. Stephens burn injury,
without professional medical assistance or supervision. Defendant OHSU knew or should
have known that Plaintiff Karellen and Renee were not suited to care for such an injury at
their home and would suffer undue emotional trauma and hardship caring for Plaintiff Q.
Stephens burn injury.
263. Defendant OHSU failed to treat Plaintiff Q. Stephens for her burn injury by not
transferring her to the Oregon Burn Center and by failing to administer basic trauma care.
Defendant OHSU knew or should have known that children diagnosed with severe burn
injuries (i.e., partial thickness burns greater than 10% total body surface area (TBSA); burns
that involve the face, hands, feet, genitalia, perineum, or major joints; and/or burned children
in hospitals without qualified personnel or equipment for the care of children) should be
transferred immediately to the nearest specialized burn treatment facility, as recommended
by the American Burn Association.
264. Defendant OHSU failed to report Plaintiff Q. Stephens burn injury to the proper
authorities (i.e. DHS or the Portland Police) which is required by state and federal child
abuse laws.
265. Defendant OHSU inserted unverified, baseless, and uninvestigated information into
Plaintiff Qadiras medical record.
266. Defendant OHSU failed to treat Plaintiff Q. Stephens multiple times.
267. Defendant OHSU intended to let Plaintiff Q Stephens die from organ failure or sepsis.

268. Defendants think it is okay to play naked games with children, injure them, and take zero
responsibility if the act is committed by a person or persons who are white, wealthy, and
related to someone importance.
269. Defendants think that it is okay to verbally, physically, and psychologically harass non-
white persons on the job and just in general and that such harassment should just be
considered a bunch of crude jokes and that non-white persons do not deserve a safe and
healthy work environment or the right to life or any rights at all.
270. On or about August 2011 Defendant Cares Northwest refused to interview Plaintiff Q.
Stephens to determine whether she had been a victim of child abuse and refused to render her
any services because she is not White, wealthy, or related to anyone of importance.
VII. DAMAGES
271. The plaintiffs have experienced excess mental suffering and severe emotional distress
in the form of unnecessary weight-gain, weight loss, insomnia, depression, feelings of
parental inadequacy, loss of quality of life, financial devastation, loss of a societal structure
in which to reside, public humiliation, degradation, excessive worry, panic attacks,
inconvenience, and loss of the ability to trust an attorney, the judicial process, the
government, police, school district, hospital and the entire American system. As a direct
result of the defendants negligence Plaintiff Q. Stephens has suffered the development of
medical complications stemming from her untreated burn injury such as Type 1 Diabetes
Mellitus, Osteopenia, Scoliosis, and other not yet known conditions. Plaintiffs also no
longer feel safe or welcome in their own community or in their own country. The Plaintiffs
cannot get honest medical attention for Qadira.


VIII. PRAYER FOR RELIEF
WHEREFORE, the plaintiff respectfully requests that this Court grant the following
relief:
a. That the Stephens family be placed immediately under federal protection to
ensure their safety and the safety of their children.
b. That Plaintiff Q Stephens be immediately granted an independent assessment of
her health by at least 2 hospitals and 2 burn experts independent of the State of
Oregon and Defendant Nike to ensure her ongoing physical safety.
c. That the Stephens family be given counsel and crime victims services in order to
process the actions taken against them.
d. That this Court immediately nullifies all of the proceedings in Plaintiff K, R and
Q Stephens State and Federal cases in favor of letting this case move forward
unimpeded.
e. That this court declare that the practice of courts granting motions for summary
judgment or motions to dismiss without opinion, explanation, or without
addressing the genuine issues of material fact presented by a litigant an
unconstitutional practice and in violation of the VII and XIV Amendments to the
U.S. Constitution.
f. That this court declare that motions for summary judgment and motions to
dismiss will only be granted with, reason, opinion and explanation to support its
rulings that show how the motions are proper and grounded in the law and court
rules and how the genuine issues of material fact have been addressed.
g. That this Court directs the Federal Bureau ofInvestigation to do its job and to
properly and thoroughly investigate this matter and all the surrounding
circumstances for potential federal crimes perpetrated by the defendants.
h. That this Court impanels a grand jury review of the facts of this case for
indictment and prosecution ofpotential state and federal crimes perpetrated by the
defendants.
1. That this Court awards the plaintiffs non-economic and punitive damages in the
sum of$II,110,000.00
J. That this Court award the plaintiffs costs and court fees.
k. That this Court grants the plaintiffs such other and further relief as this Court
finds necessary and proper.
IX. JURY DEMAND
Plaintiff demands a trial by jury on all issues of facts and damages in this action.
We declare under penalty of perjury that the foregoing is true and correct.
Dated: July 3, 2012
7135 SW 54
th
Avenue
Portland, OR 97219
503-977 -7935
karellen.stephens@comcast.net
renee. stephens 1 @comcast.net
Plaintiffs in Pro Se
Page 68 COMPLAINT FOR DEPRNATION OF RIGHTS, CONSPIRACY TO INTERFERE
WITH CNIL RIGHTS, NEGLECT TO PREVENT, ETC.

PAGE 1 CERTIFICATE OF SERVICE

Karellen and ReneeStephens, Pro Se,
7135 SW 54
th
Ave.
Portland, OR 97219
503-977-7935

CERTIFICATE OF SERVICE

I hereby certify that I served the foregoing PLAINTIFF STEPHENS SECOND
AMENDED COMPLAINT on the following named person(s) on the date indicated below.

[ ] mailing with paid postage
[ ] hand delivery
[ ] facsimile transmission
[ ] overnight delivery
[ x ] email
to said person(s) a true copy thereof, contained in a sealed envelope, addressed to said
person(s) at their last-known address(es) indicated below.

Stephen C. Voorhees, OSB No.794311
svoorhees@kilmerlaw.com
Candice Broock, OSB No. 025200
cbroock@kilmerlaw.com
Kilmer, Voorhees & Laurick, P.C.
Attorneys at Law
732 N.W. 19
th
Avenue
Portland, Oregon 97209-1302
Telephone: 503-224-0055
Fax: 503-222-5290
Of Attorneys for Defendants Scott Kocher,
Richard Vangelisti, and Vangelisti Kocher,
LLP.
Ralph C. Spooner, OSB No. 73288
E-mail: rspooner@smapc.com
SPOONER & MUCH, P.C.
530 Center Street N.E., Suite 722
Salem, OR 97301
Phone: 503-378-7777
Fax: 503-588-5899
Attorney for Defendants
Beth Phipps and Susan OLeary
Karen OKasey, OSB No. 870696
E-Mail: kok@hartwagner.com
HART WAGNER LLP
1000 S.W. Broadway, Twentieth Floor
Portland, Oregon 97205
Telephone: (503) 222-4499
Facsimile: (503) 222-2301
Of Attorneys for OHSU
Defendants

PAGE 2 CERTIFICATE OF SERVICE

Karellen and ReneeStephens, Pro Se,
7135 SW 54
th
Ave.
Portland, OR 97219
503-977-7935

Amber A. Hollister, OSB No. 035458
ahollister@osbar.org
Helen M. Hierschbiel, OSB No. 975422
OREGON STATE BAR
16037 SW Upper Boones Ferry Rd.
P.O. Box 231935
Tigard, Oregon 9728-1935
Telephone: (503) 431-6312
Facsimile: (503) 598-6912
Attorneys for Defendants Oregon State
Bar, Scott A. Morrill, and Sylvia E.
Stevens
George S. Pitcher, OSB #963982
gpitcher@williamskastner.com
Rachel A. Robinson, OSB #084550
rrobinson@williamskastner.com
WILLIAMS, KASTNER & GIBBS PLLC
888 SW Fifth Avenue, Suite 600
Portland, OR 97204-2025
Phone: (503) 228-7967
Fax: (503) 222-7261
Attorneys for defendant John Barker
JENNY M. MORF, ACTING COUNTY
ATTORNEY FOR MULTNOMAH COUNTY,
OREGON
Susan M. Dunaway, OSB No. 970506
Assistant County Attorney
501 S.E. Hawthorne Blvd., Suite 500
Portland, Oregon 97214
Telephone: (503) 988-3138
Facsimile: (503) 988-3377
Email: susan.m.dunaway@multco.us
Of Attorneys for Multnomah County
Peter O. Tuenge, OSB #034814
ptuenge@keatingjones.com
Jamie E. Valentine, OSB #075556
jvalentine@keatingjones.com
Keating Jones Hughes PC
One SW Columbia, Suite 800
Portland, OR 97258-2095
Phone: (503) 222-9955
Fax: (503) 796-0699
Attorneys for Jlie W. Andrews, MD; Oregon
Emergency Physicians
Elmer M. Dickens, OSB No. 98048
Senior Assistant County Counsel
Elmer_dickens@co.washington.or.us
Office of Washinton County Counsel
155 N. First Ave., Suite 340-MS 24
Hillsboro, OR 97124-3072
Phone (503) 846-8747
Fax (503) 846-8636
Attorney for Defendant Washington County
KAREN M. VICKERS, OSB No. 91381
kvickers@mershanlaw.com
BLAKE H. FRY, OSB No. 100128
bfry@mershanlaw.com
MERSEREAU SHANNON LLP
One SW Columbia Street, Suite 1600
Telephone: 503.226.6400
Facsimile: 503.226.0383
Of Attorneys for Defendant Portland
Public Schools
Paul Silver, OSB #783791
Email: psilver@lindsayhart.com
Katie Eichner, OSB #093405
Email: keichner@lindsayhart.com
LINDSAY, HART, NEIL & WEIGLER, LLP
Phone: 503-226-7677
Fax: 503-226-7697
Attorneys for Defendants
JOHN R. KROGER
Attorney General
HEATHER J. VAN METER #983625
Senior Assistant Attorney General
Department ofJustice
1162 Court Street NE
Salem, OR 97301-4096
Telephone: (503) 947-4700
Fax: (503) 947-4791
Email: heather.j.vanmeter@doj.state.or.us
Attorney for Defendants
DATED: July 3,2012.
Amy Joseph Pedersen, OSB No. 853958
ajpedersen@stoel.com
Melissa 1. Healy, OSB No. 102176
mjhealy@stoel.com
STOEL RIVES LLP
Portland, OR 97204
Telephone: (503) 224-3380
Facsimile: (503) 220-2480
Attorneys for Defendants Nike, Inc. and Phil
Knight
DAVID LANDRUM, OSB No. 955425
Deputy City Attorney
Email: david.landrum@portlandoregon.gov
Office of City Attorney
1221 SW 4th Avenue, Rm 430
OR 97204
Telephone: (503) 823-4047
Facsimile: (503) 823-3089
Attorney for Defendant City ofPortland

RtMee Stephens
7135 SW 54
th
Avenue
Portland, OR 97219
503-977-7935
renee.stephens l@comcast.net
Plaintiff in Pro Se
PAGE 3 -CERTIFICATE OF SERVICE
Karellen and ReneeStepbens, Pro Se,
7135 SW 54'" Ave.
Portland, OR 97219
503-977-7935

Qadira Stephens v. Multnomah County OHSU Providence For Malpractice, Child Abuse, Burn, Hate Crime

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