Circuit Complaint

1 2 3 4 5 6 7 8 9

IN THE CIRCUIT

FOR THE COUNTY OF MULTNOMAH

10 11 12 13 14 15 16 17 18 19

20 21 22 23

COURT OF THE STATE OF OREGON

CHARLES

) ) ) ) ) ) ) ) ) )

T. WENNING,

Plaintiff,

v. TOM POTTER, RANDY LEONARD, and DAN SALTZMAN, Defendants.

No.

1.

24

The said plaintiff,

Charles

T. Wenning,

is a tax-

25 paying resident of Portland, State of Oregon, who was 26 harassed,

assaulted,

had his personal

27 and whose civil rights were violated 28

property

on July 7, and July

14, 2008, at the VOZ Day Labor Site, by clients

29 Day Labor Site. 30 Portland,

Tom Potter is Mayor

State of Oregon.

31 are City Councilmen 32 Oregon.

Page 1 - COMPLAINT

destroyed,

of the VOZ

of the City of

Randy Leonard

and Dan Saltzman

of the City of Portland,

State of

2.

1 2

The said defendants and each of them are engaged

3 in on-going criminal activity, by providing $200,000.00 of 4 public funds, on or about March 5, 2008, to support 5 criminal activity at the VOZ Day Labor Site at 240 N.E. 6 Martin Luther King Blvd., Portland, Oregon, by funding VOZ 7 I.pa.y

Labor

Site for the purpose

8

aliens who are not authorized

9

States,

in violation

of U.S.

of employment to be employed

Code

8, Section

of illegal in the United 1324 (a) (1) (A)

10 (v); Portland City Code 1.03.050 A; Portland, Oregon's oath 11

of office; ORS 294.100;

12

to authorize

13

United

14

violates U.S. Code and the Supremacy Clause of the United

15

States Constitution.

and ORS 162.405.

these funds is legally

States Constitution,

because

16

The City action

ineffective

under

the

the City action

3.

17

The said Defendants

18

and continuing

19

State of Oregon,

on or about June 16, 2008,

to this day, in the County did unlawfully:

20

4

21

Harbor

22

Code

23

03.050A;

8, Section

of Multnomah

.

illegal aliens in violation 1324 (a) (1) (A) (iii);

Portland,

24 and ORS 162.405. 25

Page 2 - COMPLAINT

Oregon's

oath

Portland

of office;

of U.S. City ORS

Code

294.100;

1.

5.

1 2

Encourage

illegal

aliens to enter and/or

3 I

in the United states in violation

4

1324 (a) (1) (A) (iv);

Portland

City

reside

of U.s. Code 8, Section Code

1.03.050

A;

Portland,

5 Oregon's oath of office; ORS 294.100; and ORS 162.405. 6.

6 7

Aid and abet the harboring of illegal aliens, aid

8 and abet the encouragement

of illegal aliens

to enter

9 and/or reside in the United States, and aid and abet a 10

conspiracy to do each, in violation of U.s. Code 8, Section

11

1324 (a) (1) (A) ii,

12

Oregon's

oath

Portland

of office;

City ORS

Code

1.03.050

294.100;

and

14

Unlawfully violation

162.405.

WHEREFORE,

17

1.

18

VOZ Day Labor

19

Portland,

operation

prays

activity

in

for relief as follows:

to halt operations

Site at 240 N.E. Martin

of the

Luther King Blvd.,

Oregon; Defendants

repay all monies

granted

for

of the VOZ Day Labor Site;

3.

22

Plaintiff

For an injunction

2.

20

engage in racketeering

of ORS 166.720.

16

21

ORS

Portland,

7.

13

15

A;

23

to the assaults

24

Site.

For $500.00 for pain and suffering

related

on July 7 and July 14 at the VOZ Day Labor

25

Page 3 - COMPLAINT

1

4.

21'resulting

from the incidents

For $283.00 for damage to two cameras on July 7 and July 14 at the

3 VOZ Day Labor Site. 4

5.

For $5,000.00 for violations of my civil

5 rights on July 7 and July 14 at the VOZ Day Labor Site. 6.

6 7 determined 8

For punitive

damages

in an amount

at trial. DATED

this

day of July, 2008.

9 10 11

Charles T. Wenning 4224 S.E. Cora Portland, OR 97206 (503) 772-0293

12 13

14 15 16 17 18 19

20

21 22 23 24

25 26 27 28

Page 4

-

COMPLAINT

to be