Complaint for Money Damages for Non-Delivery of

Cargo page 1
VI JEAN RENO
1420 Fifth Avenue, Suite 3000
Seattle, WA 98101
(206) 622-4100

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE


TA TRIUMPH-ADLER GMBH, a
German foreign company; ERGO
VERSICHERUNG AG, a German
foreign company; INTERMEC
INTERNATIONAL BV, a Dutch foreign
company; NATIONAL UNION FIRE
INSURANCE COMPANY OF
PITTSBURG, PA, a New York
corporation; BEST BUY CO., INC.,
Minnesota corporation; HONGFUJ IN
PRECISION ELECTRONICS
(CHONGQING) CO., LTD., a Chinese
foreign limited liability company; AIG
TAIWAN INSURANCE CO. LTD., a
Taiwanese foreign limited liability
company; FUBON INSURANCE CO.,
LTD, a Taiwanese foreign limited
liability company; TAIWAN FIRE &
MARINE INSURANCE CO. LTD., a
Taiwanese foreign limited liability
company; CATHAY CENTURY
INSURANCE CO., LTD, a Taiwanese
foreign limited liability company;
UNION INSURANCE CO., LTD, a
Taiwanese foreign limited liability
company; INSURANCE COMPANY OF
NORTH AMERICA, TAIWAN
BRANCH, a Taiwanese foreign limited
liability company; PICC PROPERTY
AND CASUALTY COMPANY
IN ADMIRALTY AND AT LAW

Cause No.


COMPLAINT FOR MONEY DAMAGES
FOR NON-DELIVERY OF CARGO
Case 2:14-cv-00975-JCC Document 1 Filed 07/01/14 Page 1 of 14


Complaint for Money Damages for Non-Delivery of
Cargo page 2
VI JEAN RENO
1420 Fifth Avenue, Suite 3000
Seattle, WA 98101
(206) 622-4100

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LIMITED, a Chinese foreign limited
liability company; GIBSON BRANDS,
INC., f/k/a GIBSON GUITAR CORP., a
Tennessee corporation; ROYAL & SUN
ALLIANCE INSURANCE PLC., a
United Kingdom foreign company;
CORSAIR COMPONENTS, INC., a
Delaware corporation; FALVEY
CARGO UNDERWRITING, a Rhode
Island corporation; INDIGO VISION
LTD., a United Kingdom foreign limited
liability company; AVIVA
INSURANCE UK LIMITED, a United
Kingdom foreign limited liability
company; THE MAD GROUP (HQ)
LTD., a United Kingdom foreign limited
liability company; THULE SWEDEN
AB, a Swedish foreign company; XL
INSURANCE COMPANY LTD., a
Swedish foreign company,

Plaintiffs,

v.

EXPEDITORS INTERNATIONAL OF
WASHINGTON, INC., a Washington
corporation; and EXPEDITORS
INTERNATIONAL OCEAN, INC., a
Washington corporation.

Defendants.




COME NOW the Plaintiffs as set forth more fully below and for complaint against the
defendants, allege as follows:
PARTIES
1. Plaintiff TA TRIUMPH-ADLER (hereinafter Triumph-Adler) is a German
company with it principal place of business located in Norderstedt, Germany, and was the owner
of 784 cartons of copiers, the cargo.
Case 2:14-cv-00975-JCC Document 1 Filed 07/01/14 Page 2 of 14


Complaint for Money Damages for Non-Delivery of
Cargo page 3
VI JEAN RENO
1420 Fifth Avenue, Suite 3000
Seattle, WA 98101
(206) 622-4100

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2. Plaintiff ERGO VERSICHERUNG AG (hereinafter Ergo) is a German
insurance company, which is formed under the laws of Germany, located in Dusseldorf,
Germany, and was the insurer of said cargo described in 1.
3. Plaintiff INTERMEC INTERNATIONAL BV (hereinafter Intermec) is a Dutch
company with its principal place of business located in Nijmegen, The Netherlands, and was the
owner of 160 cartons of assorted electrical parts, the cargo.
4. Plaintiff BEST BUY CO., INC. (hereinafter Best Buy) is a Minnesota company
with its principal place of business located in Richfield, Minnesota, and was the owner of 416
cartons of micro-USB car chargers, the cargo.
5. Plaintiff NATIONAL UNION FIRE INSURANCE COMPANY OF
PITTSBURGH, PA (hereinafter National Union) is a New York insurance company which is
formed under the laws of Pennsylvania, and has its principal place of business in New York City,
New York, and was the insurer of said cargo described in 3 and 4.
6. Plaintiff HONGFUJ IN PRECISION ELECTRONICS (CHONGQING) CO.,
LTD. (hereinafter HPE) is a Chinese company with its principal place of business located in
Beijing, China, and was the owner of 140 LCD Monitor parts, the cargo.
7. Plaintiff AIG TAIWAN INSURANCE CO. LTD; FUBON INSURANCE CO.,
LTD; TAIWAN FIRE & MARINE INSURANCE CO. LTD; CATHAY CENTURY
INSURANCE CO. LTD; UNION INSURANCE CO. LTD; and INSURANCE COMPANY OF
NORTH AMERICA, TAIWAN BRANCH (hereinafter, collectively, AIG) are Taiwanese
insurance companies, formed under the laws of Taiwan, located in Taipei, Taiwan, and the
insurers of said cargo described in 6.
Case 2:14-cv-00975-JCC Document 1 Filed 07/01/14 Page 3 of 14


Complaint for Money Damages for Non-Delivery of
Cargo page 4
VI JEAN RENO
1420 Fifth Avenue, Suite 3000
Seattle, WA 98101
(206) 622-4100

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8. Plaintiff PICC PROPERTY AND CASUALTY COMPANY LIMITED
(hereinafter PCC) is a Chinese insurance company, which is formed under the laws of China,
located in Beijing, and were also the insurers of said cargo described in 6.
9. Plaintiff GIBSON BRANDS, INC, f/k/a GIBSON GUITAR CORP. (hereinafter
Gibson) is a Tennessee company with its principal place of business located in Nashville,
Tennessee, and was the owner of 100 turntable USB sets with carts, the cargo.
10. Plaintiff ROYAL & SUN ALLIANCE INSURANCE PLC (hereinafter Royal &
Sun) is an English insurance company which is formed under the laws of the United Kingdom,
and has its principal place of business in London, England, was the insurer of said cargo
described in 9.
11. Plaintiff CORSAIR COMPONENTS, INC. (hereinafter Corsair) is a Delaware
company with it principal place of business located in Fremont, California, and was the owner of
2,374 cartons of various computer accessories, the cargo.
12. Plaintiff FALVEY CARGO UNDERWRITING (hereinafter Falvey) is a Rhode
Island insurance company, which is formed under the laws of Rhode Island, located in North
Kingstown, Rhode Island, and was the insurer of said cargo described in 11.
13. Plaintiff INDIGO VISION LTD. (hereinafter Indigo) is a United Kingdom
company with its principal place of business in Edinburgh, Scotland, and was the owner of 402
cartons of assorted electrical parts, the cargo.
14. Plaintiff AVIVA INSURANCE UK LIMITED (hereinafter Aviva) is an
English insurance company which is formed under the laws of the United Kingdom, and has its
principal place of business in Norfolk, England, and was the insurer of said electrical parts cargo
described in 13.
Case 2:14-cv-00975-JCC Document 1 Filed 07/01/14 Page 4 of 14


Complaint for Money Damages for Non-Delivery of
Cargo page 5
VI JEAN RENO
1420 Fifth Avenue, Suite 3000
Seattle, WA 98101
(206) 622-4100

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15. Plaintiff THE MAD GROUP (HQ) LTD (hereinafter Mad Group) is a United
Kingdom company with its principal place of business in Worcestershire, England, and was the
owner of 486 cartons of assorted yoga/pilates equipment, the cargo.
16. Plaintiff ROYAL & SUN ALLIANCE INSURANCE PLC (hereinafter Royal &
Sun) is an English insurance company which is formed under the laws of the United Kingdom,
and has its principal place of business in London, England, and was the insurer of said cargo
described in 15.
17. Plaintiff THULE SWEDEN AB (hereinafter Thule) is a Swedish company with
its principal place of business located in Hillerstorp, Sweden, and was the owner of 1,700 cartons
of Daypacks, the cargo.
18. Plaintiff XL INSURANCE COMPANY LTD. (hereinafter XL) is a Swedish
insurance company, which is formed under the laws of Sweden, and has its principal place of
business in Stockholm, Sweden, and was the insurer of said cargo described in 17.
19. Plaintiffs are informed and believe and on the basis of that information and belief
allege that EXPEDITORS INTERNATIONAL OF WASHINGTON, INC., and EXPEDITORS
INTERNATIONAL OCEAN, INC. (hereinafter Expeditors) are Washington companies whose
principal place of business is located in Seattle, Washington, and now and at all times herein
material were engaged in business as a common carrier for hire within the United States and
within this judicial district.
JURISDICTION AND VENUE
20. This is a cause of action for damage to ocean cargo arising under a maritime
contract for transportation of goods in international waters, and is an admiralty and maritime
claim within the meaning of Rule 9(h), Federal Rules of Civil Procedure, as hereinafter more
Case 2:14-cv-00975-JCC Document 1 Filed 07/01/14 Page 5 of 14


Complaint for Money Damages for Non-Delivery of
Cargo page 6
VI JEAN RENO
1420 Fifth Avenue, Suite 3000
Seattle, WA 98101
(206) 622-4100

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fully appears. This Court has jurisdiction upon the basis of 28 U.S.C. 1333.
21. Venue is proper in this Court under 28 U.S.C. 1391(b)(1), as the defendants
reside in this judicial district.
FACTS
22. Plaintiffs Triumph-Adler and Ergo are informed and believe that on or about May
26, 2013, at Kobe, J apan, defendant Expeditors received a shipment of various types of cargo
owned by plaintiff Triumph-Adler, for carriage under bill of lading number 6940086679, and
others, issued by and/or on behalf of said defendant. Expeditors agreed, under contracts of
carriage and in return for good and valuable consideration, to carry said cargo from Kobe, J apan,
to Hamburg, Germany, and there deliver said cargo to the lawful holder of the aforementioned
bill of lading, and others, in the same good order, condition, and quantity as when received.
23. Thereafter, in breach of and in violation of said agreements, Expeditors did not
deliver said cargo in the same good order, condition, and quantity as when received at J apan. To
the contrary, Expeditors failed to deliver the cargo. The value of the non-delivered cargo was
$415,469.16.
24. Prior to the shipment of the cargo described herein and prior to any loss thereto,
plaintiff Ergo issued its policy of insurance whereby plaintiff Ergo agreed to indemnify
Triumph-Adler, and its assigns, against loss of or damage to said cargo while in transit, including
mitigation expenses, and plaintiff Ergo has therefore become obligated to pay, and has paid to
the person entitled to payment under said policy the sum of $415,469.16, on account of the
herein described loss.
25. Plaintiff Ergo has therefore been damaged in the sum of $415,469.16, or another
amount according to proof at trial, no part of which has been paid, despite demand therefor.
Case 2:14-cv-00975-JCC Document 1 Filed 07/01/14 Page 6 of 14


Complaint for Money Damages for Non-Delivery of
Cargo page 7
VI JEAN RENO
1420 Fifth Avenue, Suite 3000
Seattle, WA 98101
(206) 622-4100

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26. Plaintiffs Intermec and National Union are informed and believe that on or about
J une 4, 2013, at Dongguan, China, defendant Expeditors received a shipment of various types of
cargo owned by plaintiff Intermec, for carriage under bills of lading number 614625540 and
614625554, and others, issued by and/or on behalf of said defendant. Expeditors agreed, under
contracts of carriage and in return for good and valuable consideration, to carry said cargo from
Dongguan, China, to Rotterdam, Netherlands, and there deliver said cargo to the lawful holder of
the aforementioned bills of lading, and others, in the same good order, condition, and quantity as
when received.
27. Thereafter, in breach of and in violation of said agreements, Expeditors did not
deliver said cargo in the same good order, condition, and quantity as when received at China. To
the contrary, Expeditors failed to deliver the cargo. The value of the non-delivered cargo was
$33,872.40.
28. Prior to the shipment of the herein described cargo and prior to any loss thereto,
plaintiff National Union issued its policy of insurance whereby plaintiff National Union agreed
to indemnify Intermec, and its assigns, against loss of or damage to said cargo while in transit,
including mitigation expenses, and plaintiff National Union has therefore become obligated to
pay, and has paid to the person entitled to payment under said policy the sum of $33,872.40, on
account of the herein described loss.
29. Plaintiff National Union has therefore been damaged in the sum of $33,872.40, or
another amount according to proof at trial, no part of which has been paid, despite demand
therefor.
30. Plaintiffs Best Buy and National Union are informed and believe that on or about
J une 4, 2013, at Dongguan, China, defendant Expeditors received a shipment of various types of
Case 2:14-cv-00975-JCC Document 1 Filed 07/01/14 Page 7 of 14


Complaint for Money Damages for Non-Delivery of
Cargo page 8
VI JEAN RENO
1420 Fifth Avenue, Suite 3000
Seattle, WA 98101
(206) 622-4100

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cargo owned by plaintiff Best Buy, for carriage under bill of lading number 6911064478, and
others, issued by and/or on behalf of said defendant. Expeditors agreed, under contracts of
carriage and in return for good and valuable consideration, to carry said cargo from China, to
Gothenburg, Sweden, and there deliver said cargo to the lawful holder of the aforementioned
bills of lading, and others, in the same good order, condition, and quantity as when received.
31. Thereafter, in breach of and in violation of said agreements, Expeditors did not
deliver said cargo in the same good order, condition, and quantity as when received. To the
contrary, Expeditors failed to deliver the cargo. The value of the non-delivered cargo was
$26,357.76.
32. Prior to the shipment of the herein described cargo and prior to any loss thereto,
plaintiff National Union issued its policy of insurance whereby plaintiff National Union agreed
to indemnify Best Buy of said cargo, against loss of or damage to said cargo while in transit,
including mitigation expenses, and plaintiff National Union has therefore become obligated to
pay, and has paid to the person entitled to payment under said policy the sum of $26,357.76, on
account of the herein described loss.
33. Plaintiff National Union has therefore been damaged in the sum of $26,357.76, or
another amount according to proof at trial, no part of which has been paid, despite demand
therefor.
34. Plaintiffs HPE, AIG, and PICC are informed and believe that on or about J une 4,
2013, at Dongguan, China, defendant Expeditors received a shipment of various types of cargo
owned by plaintiff HPE, for carriage under bill of lading number 614625551, and others, issued
by and/or on behalf of said defendant. Expeditors agreed, under contracts of carriage and in
return for good and valuable consideration, to carry said cargo from Dongguan, China, to
Case 2:14-cv-00975-JCC Document 1 Filed 07/01/14 Page 8 of 14


Complaint for Money Damages for Non-Delivery of
Cargo page 9
VI JEAN RENO
1420 Fifth Avenue, Suite 3000
Seattle, WA 98101
(206) 622-4100

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Warsaw, Poland, via Hong Kong and Hamburg, Germany, and there deliver said cargo to the
lawful holder of the aforementioned bill of lading, and others, in the same good order, condition,
and quantity as when received.
35. Thereafter, in breach of and in violation of said agreements, Expeditors did not
deliver said cargo in the same good order, condition, and quantity as when received in China. To
the contrary, Expeditors failed to deliver the cargo. The value of the non-delivered cargo was
$2,497.30.
36. Prior to the shipment of the herein described cargo and prior to any loss thereto,
plaintiffs AIG and PICC issued their policy of insurance whereby plaintiffs AIG and PICC
agreed to indemnify HPE, and its assigns, against loss of or damage to said cargo while in transit,
including mitigation expenses, and plaintiffs AIG and PICC have therefore become obligated to
pay, and have paid to the person entitled to payment under said policy the sum of $2,497.30, on
account of the herein described loss.
37. Plaintiffs AIG and PICC have therefore been damaged in the sum of $2,497.30, or
another amount according to proof at trial, no part of which has been paid, despite demand
therefor.
38. Plaintiffs Gibson and Royal & Sun are informed and believe that on or about J une
4, 2013, at Hong Kong, defendant Expeditors received a shipment of various types of cargo
owned by plaintiff Gibson, for carriage under bill of lading number 6911063303, and others,
issued by and/or on behalf of said defendant. Expeditors agreed, under contracts of carriage and
in return for good and valuable consideration, to carry said cargo from Hong Kong, to
Rotterdam, Netherlands, and there deliver said cargo to the lawful holder of the aforementioned
bill of lading, and others, in the same good order, condition, and quantity as when received.
Case 2:14-cv-00975-JCC Document 1 Filed 07/01/14 Page 9 of 14


Complaint for Money Damages for Non-Delivery of
Cargo page 10
VI JEAN RENO
1420 Fifth Avenue, Suite 3000
Seattle, WA 98101
(206) 622-4100

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39. Thereafter, in breach of and in violation of said agreements, Expeditors did not
deliver said cargo in the same good order, condition, and quantity as when received at Hong
Kong. To the contrary, Expeditors failed to deliver the cargo. The value of the non-delivered
cargo was $8,813.00.
40. Prior to the shipment of the herein described cargo and prior to any loss thereto,
plaintiff Royal & Sun issued its policy of insurance whereby plaintiff Royal & Sun agreed to
indemnify Gibson, and its assigns, against loss of or damage to said cargo while in transit,
including mitigation expenses, and plaintiff Royal & Sun has therefore become obligated to pay,
and has paid to the person entitled to payment under said policy the sum of $8,813.00, on
account of the herein described loss.
41. Plaintiff Royal & Sun has therefore been damaged in the sum of $8,813.00, or
another amount according to proof at trial, no part of which has been paid, despite demand
therefor.
42. Plaintiffs Corsair and Falvey are informed and believe that on or about J une 4,
2013, at Hong Kong, defendant Expeditors received a shipment of various types of cargo owned
by plaintiff Corsair, for carriage under bills of lading numbers 6911064265 and 6911064266, and
others, issued by and/or on behalf of said defendant. Expeditors agreed, under contracts of
carriage and in return for good and valuable consideration, to carry said cargo from Hong Kong,
to Rotterdam, Netherlands, and there deliver said cargo to the lawful holder of the
aforementioned bills of lading, and others, in the same good order, condition, and quantity as
when received.
43. Thereafter, in breach of and in violation of said agreements, Expeditors did not
deliver said cargo in the same good order, condition, and quantity as when received at Hong
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Complaint for Money Damages for Non-Delivery of
Cargo page 11
VI JEAN RENO
1420 Fifth Avenue, Suite 3000
Seattle, WA 98101
(206) 622-4100

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Kong. To the contrary, Expeditors failed to deliver the cargo. The value of the non-delivered
cargo was $249,466.75.
44. Prior to the shipment of the herein described cargo and prior to any loss thereto,
plaintiff Falvey issued its policy of insurance whereby plaintiff Falvey agreed to indemnify
Corsair, and its assigns, against loss of or damage to said cargo while in transit, including
mitigation expenses, and plaintiff Falvey has therefore become obligated to pay, and has paid to
the person entitled to payment under said policy the sum of $224,446.75, excluding plaintiff
Corsairs $25,000.00 deductible, on account of the herein described loss.
45. Plaintiffs Corsair and Falvey have therefore been damaged in the sum of
$249,466.75, or another amount according to proof at trial, no part of which has been paid,
despite demand therefor.
46. Plaintiffs Indigo and Aviva are informed and believe that on or about J une 6,
2013, at Pasir Gudang, Malaysia, defendant Expeditors received a shipment of various types of
cargo owned by plaintiff Aviva, for carriage under bill of lading number 612620204, and others,
issued by and/or on behalf of said defendant. Expeditors agreed, under contracts of carriage and
in return for good and valuable consideration, to carry said cargo from Pasir Gudang, Malaysia,
to Grangemouth, United Kingdom, and there deliver said cargo to the lawful holder of the
aforementioned bill of lading, and others, in the same good order, condition, and quantity as
when received.
47. Thereafter, in breach of and in violation of said agreements, Expeditors did not
deliver said cargo in the same good order, condition, and quantity as when received at Malaysia.
To the contrary, Expeditors failed to deliver the cargo. The value of the non-delivered cargo was
$63,063.00.
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Complaint for Money Damages for Non-Delivery of
Cargo page 12
VI JEAN RENO
1420 Fifth Avenue, Suite 3000
Seattle, WA 98101
(206) 622-4100

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48. Prior to the shipment of the herein described cargo and prior to any loss thereto,
plaintiff Aviva issued its policy of insurance whereby plaintiff Aviva agreed to indemnify
Indigo, and its assigns, against loss of or damage to said cargo while in transit, including
mitigation expenses, and plaintiff Aviva has therefore become obligated to pay, and has paid to
the person entitled to payment under said policy the sum of $63,063.00, on account of the herein
described loss.
49. Plaintiff Aviva has therefore been damaged in the sum of $63,063.00, or another
amount according to proof at trial, no part of which has been paid, despite demand therefor.
50. Plaintiffs Mad Group and Royal & Sun are informed and believe that on or about
J une 8, 2013, at Ho Chi Mihn City, Vietnam, defendant Expeditors received a shipment of
various types of cargo owned by plaintiff Mad Group, for carriage under bill of lading number
614552273, and others, issued by and/or on behalf of said defendant. Expeditors agreed, under
contracts of carriage and in return for good and valuable consideration, to carry said cargo from
Ho Chi Mihn City, Viet Nam, to Southampton, England, and there deliver said cargo to the
lawful holder of the aforementioned bill of lading, and others, in the same good order, condition,
and quantity as when received.
51. Thereafter, in breach of and in violation of said agreements, Expeditors did not
deliver said cargo in the same good order, condition, and quantity as when received at Viet Nam.
To the contrary, Expeditors failed to deliver the cargo. The value of the non-delivered cargo was
$19,058.97.
52. Prior to the shipment of the herein described cargo and prior to any loss thereto,
plaintiff Royal & Sun issued its policy of insurance whereby plaintiff Royal & Sun agreed to
indemnify Mad Group, and its assigns, against loss of or damage to said cargo while in transit,
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Complaint for Money Damages for Non-Delivery of
Cargo page 13
VI JEAN RENO
1420 Fifth Avenue, Suite 3000
Seattle, WA 98101
(206) 622-4100

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including mitigation expenses, and plaintiff Royal & Sun has therefore become obligated to pay,
and has paid to the person entitled to payment under said policy the sum of $19,058.97, on
account of the herein described loss.
53. Plaintiff Royal & Sun has therefore been damaged in the sum of $19,058.97, or
another amount according to proof at trial, no part of which has been paid, despite demand
therefor.
54. Plaintiffs Thule and XL are informed and believe that on or about J une 8, 2013, at
Ho Chi Mihn City, Vietnam, defendant Expeditors received a shipment of various types of cargo
owned by plaintiff Thule, for carriage under bill of lading number 617885751, and others, issued
by and/or on behalf of said defendant. Expeditors agreed, under contracts of carriage and in
return for good and valuable consideration, to carry said cargo from Ho Chi Mihn City, Viet
Nam, to Rotterdam, Netherlands, via Vung Tau, Viet Nam, and there deliver said cargo to the
lawful holder of the aforementioned bill of lading, and others, in the same good order, condition,
and quantity as when received.
55. Thereafter, in breach of and in violation of said agreements, Expeditors did not
deliver said cargo in the same good order, condition, and quantity as when received at Viet Nam.
To the contrary, Expeditors failed to deliver the cargo. The value of the non-delivered cargo was
$73,032.00.
56. Prior to the shipment of the herein described cargo and prior to any loss thereto,
plaintiff XL issued its policy of insurance whereby plaintiff XL agreed to indemnify Thule, and
its assigns, against loss of or damage to said cargo while in transit, including mitigation
expenses, and plaintiff XL has therefore become obligated to pay, and has paid to the person
entitled to payment under said policy the sum of $73,032.00, on account of the herein described
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Complaint for Money Damages for Non-Delivery of
Cargo page 14
VI JEAN RENO
1420 Fifth Avenue, Suite 3000
Seattle, WA 98101
(206) 622-4100

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loss.
57. Plaintiff XL has therefore been damaged in the sum of $73,032.00, or another
amount according to proof at trial, no part of which has been paid, despite demand therefor.
58. Plaintiffs, together and collectively, and in the amounts set forth in detail above,
have therefore been damaged in the total sum of $891,630.34, or another amount according to
proof at trial, no part of which has been paid, despite demand therefor.

WHEREFORE, plaintiffs pray for relief as follows:
1. That judgment be entered in favor of plaintiffs and against defendants in the sum
of $891,630.34;
2. That plaintiffs be awarded prejudgment interest thereon and costs of suit herein;
and
3. For any and all other relief that this Court deems just and equitable.

Dated this 1
st
day of J uly, 2014.

VI J EAN RENO

/s/ Vi J ean Reno
Vi J ean Reno, WSBA No. 9385
Law Offices of Vi J ean Reno
1420 Fifth Avenue, Suite 3000
Seattle, WA 98101
Telephone: (206) 622-4100
Fax: (206) 464-0461
Email: vjreno@renolawsea.com
Attorneys for Plaintiffs herein
Case 2:14-cv-00975-JCC Document 1 Filed 07/01/14 Page 14 of 14