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8 IN THE CIRCUIT COURT OF THE STATE OF OREGON
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10 FOR THE COUNTY OF MULTNOMAH
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12 CHARLES T. WENNING, )
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14 Plaintiff, ) No.
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16 v. )
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18 TOM POTTER, RANDY LEONARD, )
19 and DAN SALTZMAN, )
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21 Defendants. )
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23 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 property destroyed,
27 and whose civil rights were violated on July 7, and July
28 14, 2008, at the VOZ Day Labor Site, by clients of the VOZ
29 Day Labor Site. Tom Potter is Mayor of the City of
30 Portland, State of Oregon. Randy Leonard and Dan Saltzman
31 are City Councilmen of the City of Portland, State of
32 Oregon.

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 1 2.
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 of employment of illegal

8 aliens who are not authorized to be employed in the United
9 States, in violation of U.S. Code 8, Section 1324 (a) (1) (A)

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

11 of office; ORS 294.100; and ORS 162.405. The City action
12 to authorize these funds is legally ineffective under the
13 United States Constitution, because the City action
14 violates U.S. Code and the Supremacy Clause of the United
15 States Constitution.
16 3.

17 The said Defendants on or about June 16, 2008,

18 and continuing to this day, in the County of Multnomah
19 State of Oregon, did unlawfully:
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21 Harbor illegal aliens in violation of U.S.

22 Code 8, Section 1324 (a) (1) (A) (iii); Portland City Code 1.

23 03.050A; Portland, Oregon's oath of office; ORS 294.100;

24 and ORS 162.405.

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 1 5.
2 Encourage illegal aliens to enter and/or reside
3 I in the United states in violation of U.s. Code 8, Section
4 1324 (a) (1) (A) (iv); Portland City 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, Portland City Code 1.03.050 A; Portland,

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

13 7.
14 Unlawfully engage in racketeering activity in
15 violation of ORS 166.720.

16 WHEREFORE, Plaintiff prays for relief as follows:

17 1. For an injunction to halt operations of the
18 VOZ Day Labor Site at 240 N.E. Martin Luther King Blvd.,
19 Portland, Oregon;
20 2. Defendants repay all monies granted for
21 operation of the VOZ Day Labor Site;
22 3. For $500.00 for pain and suffering related
23 to the assaults on July 7 and July 14 at the VOZ Day Labor
24 Site.

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 1 4. For $283.00 for damage to two cameras
21'resulting from the incidents 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. For punitive damages in an amount to be
7 determined at trial.

8 DATED this day of July, 2008.

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11 Charles T. Wenning
12 4224 S.E. Cora
13 Portland, OR 97206
14 (503) 772-0293
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