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`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
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`*Pro hac vice
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`Attorneys for Plaintiff
`Great Northern Resources, Inc.
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`GREAT NORTHERN RESOURCES, INC.,
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`Plaintiff,
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`UNITED STATES DISTRICT COURT
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`DISTRICT OF OREGON
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`PORTLAND DIVISION
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` Case No.: 3:20-cv-01866-IM
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`
`NOTICE OF MOTION AND MOTION
`FOR TEMPORARY RESTRAINING
`ORDER OR PRELIMINARY
`INJUNCTION
`
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`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,
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`
`
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`
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`Defendants.
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`NOTICE OF MOTION AND MOTION FOR TEMPORARY RESTRAINING ORDER OR PRELIMINARY INJUNCTION
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`Case 3:20-cv-01866-IM Document 12 Filed 11/07/20 Page 2 of 2
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`TO THE PARTIES AND THEIR ATTORNEYS OF RECORD:
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`PLEASE TAKE NOTICE that Plaintiff Great Northern Resources, Inc. ("Great
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`Northern") will and hereby does move the Court for a temporary restraining order or preliminary
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`injunction .
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`Great Northern respectfully requests a temporary restraining order or preliminary
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`injunction enjoining Defendants, or any other person or entity acting in concert with them or
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`under the authority of the State of Oregon, from using race as an essential factor in distributing
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`relief funds allocated to the state by the Federal government from the CARES Act's Coronavirus
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`Relief Fund. Defendants ' operation of the $62 million Oregon Cares Fund for Black Relief and
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`Resiliency (the "Fund") violates the Equal Protection Clause, 42 U.S.C. § 1981, and Title VI of
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`the Civil Rights Act of 1964. Immediate relief is necessary, as the Fund is required to distribute
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`all of its discriminatory grants by December 30, 2020.
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`This motion shall be based on this notice of motion and motion, the memorandum of
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`points and authorities in support, the declarations and evidence filed concurrently herewith, and
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`upon any further matters the Court deems appropriate.
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`Dated: November 7, 2020
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`BENBROOK LAW GROUP, PC
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`By
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`~ BllliNA.BNBROOK
`Attorneys for Plaintiff
`Great Northern Resources, Inc.
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`NOTICE OF MOTION AND MOTION FOR TEMPORARY RESTRAIN ING ORDER OR PRELIMINARY INJUNCTION
`-1-
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