`
`
`
`
`
`BENBROOK LAW GROUP, PC
`BRADLEY A. BENBROOK*
`STEPHEN M. DUVERNAY*
`400 Capitol Mall, Suite 2530
`Sacramento, CA 95814
`Telephone: (916) 447-4900
`Facsimile: (916) 447-4904
`brad@benbrooklawgroup.com
`steve@benbrooklawgroup.com
`
`MURPHY & BUCHAL LLP
`JAMES L. BUCHAL
`3425 SE Yamhill Street, Suite 100
`Portland, OR 97214
`Telephone: (503) 227-1011
`Facsimile (503) 573-1939
`jbuchal@mbllp.com
`
`*Pro hac vice
`
`Attorneys for Plaintiff
`Great Northern Resources, Inc.
`
`
`
`
`
`GREAT NORTHERN RESOURCES, INC.,
`
`Plaintiff,
`
`
`UNITED STATES DISTRICT COURT
`
`DISTRICT OF OREGON
`
`PORTLAND DIVISION
`
`
` Case No.: 3:20-cv-01866-IM
`
`
`NOTICE OF MOTION AND MOTION
`FOR TEMPORARY RESTRAINING
`ORDER OR PRELIMINARY
`INJUNCTION
`
`
`EXPEDITED HEARING AND ORAL
`ARGUMENT REQUESTED
`
`
`v.
`
`KATY COBA, in her Official Capacity as
`State Chief Operating Officer and Director of
`the OREGON DEPARTMENT OF
`ADMINISTRATIVE SERVICES; OREGON
`DEPARTMENT OF ADMINISTRATIVE
`SERVICES; THE CONTINGENT; and DOES
`1-10,
`
`
`
`
`
`
`Defendants.
`
`
`
`NOTICE OF MOTION AND MOTION FOR TEMPORARY RESTRAINING ORDER OR PRELIMINARY INJUNCTION
`
`
`
`
`
`Case 3:20-cv-01866-IM Document 12 Filed 11/07/20 Page 2 of 2
`
`TO THE PARTIES AND THEIR ATTORNEYS OF RECORD:
`
`PLEASE TAKE NOTICE that Plaintiff Great Northern Resources, Inc. ("Great
`
`Northern") will and hereby does move the Court for a temporary restraining order or preliminary
`
`injunction .
`
`Great Northern respectfully requests a temporary restraining order or preliminary
`
`injunction enjoining Defendants, or any other person or entity acting in concert with them or
`
`under the authority of the State of Oregon, from using race as an essential factor in distributing
`
`relief funds allocated to the state by the Federal government from the CARES Act's Coronavirus
`
`Relief Fund. Defendants ' operation of the $62 million Oregon Cares Fund for Black Relief and
`
`Resiliency (the "Fund") violates the Equal Protection Clause, 42 U.S.C. § 1981, and Title VI of
`
`the Civil Rights Act of 1964. Immediate relief is necessary, as the Fund is required to distribute
`
`all of its discriminatory grants by December 30, 2020.
`
`This motion shall be based on this notice of motion and motion, the memorandum of
`
`points and authorities in support, the declarations and evidence filed concurrently herewith, and
`
`upon any further matters the Court deems appropriate.
`
`Dated: November 7, 2020
`
`BENBROOK LAW GROUP, PC
`
`By
`
`~ BllliNA.BNBROOK
`Attorneys for Plaintiff
`Great Northern Resources, Inc.
`
`NOTICE OF MOTION AND MOTION FOR TEMPORARY RESTRAIN ING ORDER OR PRELIMINARY INJUNCTION
`-1-
`
`
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