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IN THE CIRCUIT COURT FOR THE STATE OF OREGON
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FOR MULTNOMAH COUNTY
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12 Case No.
BRANDON FARLEY
13 COMPLAINT
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Plaintiff
Battery
15 vs Injunctive Relief
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CITY OF PORTLAND Not Subject to Mandatory Arbitration
17 Amount in Controversy: $950,000
Defendant Fee Authority: ORS 21.160(1)(c)
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Jury Trial Requested
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20 1.
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FACTUAL ALLEGATIONS
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On June 4, 2020 while Mr. Farley was attending a protest in downtown
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24 Portland, City of Portland police officers opened fire on Mr. Farley and intentionally
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shot him in the knee with a rubber bullet, sending him to the hospital and causing
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him pain, discomfort and distress.
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COMPLAINT – Page 1 of 3
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2 2.
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CLAIM FOR RELIEF
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Battery
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6 The City of Portland is a municipal corporation and public body within the

7 State of Oregon located in Multnomah County. The City of Portland police officers
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who shot Mr. Farley with a rubber bullet were working under the authority and
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scope of their employment for the City of Portland Police Bureau, and so the City of
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11 Portland is legally responsible for the police officer’s behavior. As alleged in this

12 complaint, the City of Portland police officers intentionally shot Mr. Farley in the
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knee and attempted to and did cause harmful, offensive physical contact with Mr.
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Farley, causing Mr. Farley pain, discomfort and distress. Mr. Farley requests fair
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16 compensation for his harm in an amount to be determined by the jury to be

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reasonable, ranging from $1, all the way up to $950,000, whatever the jury decides
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is fair. Mr. Farley reserves the right to amend this complaint to adjust the request
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for compensation to conform to the evidence as well as to add additional defendants

21 and new claims, including a claim for punitive damages, as new information is
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learned in discovery. Mr. Farley also seeks an injunction prohibiting the City of
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Portland from continuing to use rubber bullets on peaceful protesters in the future.
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COMPLAINT – Page 2 of 3
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2 3.
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PRAYER FOR RELIEF
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Mr. Farley respectfully requests relief as sought above, and maximum
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6 interest, attorney fees, costs, disbursements, expenses, and any other relief the

7 Court deems appropriate.

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4.
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REQUEST FOR JURY TRIAL
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11 Mr. Farley respectfully requests a trial by a jury.

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June 6, 2020
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RESPECTFULLY FILED,
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16 /s/ Michael Fuller

Michael Fuller, OSB No. 09357
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Lead Trial Attorney for Plaintiff
18 OlsenDaines
US Bancorp Tower
19 111 SW 5th Ave., Suite 3150
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Portland, Oregon 97204
michael@underdoglawyer.com
21 Direct 503-222-2000
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Kelly Jones, OSB No. 074217
23 Of Attorneys for Plaintiff
The Law Office of Kelly Jones
24 kellydonovanjones@gmail.com
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COMPLAINT – Page 3 of 3