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`Case 6:21-cv-01592-MK Document 1 Filed 11/02/21 Page 1 of 13
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`Nicholas A. Kampars, OSB No. 063870
`nick.kampars@wildwoodlaw.com
`Jeanne K. Sinnott, OSB No. 075151
`jeanne.sinnott@wildwoodlaw.com
`Wildwood Law Group LLC
`3519 NE 15th Avenue, #362
`Portland, Oregon 97212
`Telephone: (503) 564-3049
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`Of Attorneys for Plaintiffs
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`IN THE UNITED STATES DISTRICT COURT
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`DISTRICT OF OREGON
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`AT EUGENE
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`v.
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`Plaintiffs,
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`NINKASI HOLDING COMPANY, INC. an
`Oregon corporation, and NINKASI
`BREWERY, LLC, an Oregon limited liability
`company,
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`
`
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`NUDE BEVERAGES, INC., a Colorado
`corporation; and MXM BEVERAGES LTD.,
`doing business as NUDE BEVERAGES CO., a
`Canadian corporation,
`
`
`
`
`Defendants.
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`PARTIES
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`1.
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`Plaintiff Ninkasi Holding Company, Inc. (“Ninkasi Holding Co.”) is an Oregon
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`corporation with its principal place of business in Eugene, Oregon. Plaintiff Ninkasi Brewery,
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`LLC (“Ninkasi Brewery”) is an Oregon limited liability company with its principal place of
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`Page 1 –COMPLAINT
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`WILDWOOD LAW GROUP LLC
`T: 503.564.3049 | F: 971.347.1425
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`3519 NE 15TH AVE #362
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`PORTLAND, OREGON 97212
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`
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`Case No.
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`COMPLAINT
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`BREACH OF CONTRACT ACTION
`(28 U.S.C. § 1332)
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`DEMAND FOR JURY TRIAL
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`Case 6:21-cv-01592-MK Document 1 Filed 11/02/21 Page 2 of 13
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`business in Eugene, Oregon.
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`2.
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`Defendant Nude Beverages, Inc. (“Nude”) is a Colorado corporation with its
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`principal place of business in Boulder, Colorado.
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`3.
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`Defendant MXM Beverages, Ltd., doing business as Nude Beverages Co.
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`(“MXM”), is a Canadian corporation with its principal place of business in Vancouver, British
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`Columbia, Canada.
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`JURISDICTION
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`4.
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`This Court has subject matter jurisdiction over this action under 28 U.S.C. § 1332
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`because Plaintiffs are citizens of Oregon and defendants are citizens of Colorado and Canada,
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`and because the amount in controversy exceeds $75,000, exclusive of interest and costs.
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`5.
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`Plaintiffs further seek a declaration of their rights in this case pursuant to 28
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`U.S.C. § 2201 and 2202.
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`VENUE
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`6.
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`Venue is proper in the United States District Court for the District of Oregon
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`because a substantial part of the events giving rise to Plaintiffs’ Claims for Relief occurred in this
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`District.
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`7.
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`Assignment to the Eugene Division is proper under District of Oregon LR 3-2
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`because the events giving rise to Plaintiffs’ Claims for Relief occurred in the Eugene Division.
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`FACTS
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`8.
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`Plaintiffs manufacture and package malt beverages and other alcohol beverage
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`products in Eugene, Oregon.
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`9.
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`Defendant Nude is in the business of developing recipes for, and brewing and
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`selling, certain hard seltzer beverage products.
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`10.
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`Defendant MXM is the parent company of defendant Nude and owns all of the
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`intellectual property under which defendant Nude sells its beverage products.
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`Page 2 –COMPLAINT
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`WILDWOOD LAW GROUP LLC
`T: 503.564.3049 | F: 971.347.1425
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`3519 NE 15TH AVE #362
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`PORTLAND, OREGON 97212
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`Case 6:21-cv-01592-MK Document 1 Filed 11/02/21 Page 3 of 13
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`11.
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`On December 21, 2019, Nude and Plaintiffs entered into a Co-Packing
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`Agreement, whereby Plaintiffs agreed to manufacture and package certain beverage products for
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`sale by Nude, among other provisions as identified in the Co-Packing Agreement.
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`12.
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`In November 2020, Nude was in the process of qualifying as a brewer, as defined
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`by the United States Alcohol and Tobacco Tax and Trade Bureau (the “TTB”) and was also in
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`the process of obtaining licensure with the Oregon Liquor Control Commission (the “OLCC”).
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`13. While Nude was awaiting its licensures, Nude and Plaintiffs entered into a
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`Manufacturing Services Agreement, dated November 19, 2020 (the “MSA”). Plaintiffs and Nude
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`agreed that the MSA replaced their prior Co-Packing Agreement and that the Co-Packing
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`Agreement terminated effective November 19, 2020. The initial term of the MSA was from
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`October 1, 2020 through January 31, 2028, unless it was terminated in accordance with the
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`MSA, and provided for two renewal terms of five (5) years, each at the option of Nude.
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`14.
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`Pursuant to the MSA, Nude engaged Ninkasi to manufacture and package certain
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`Nude products at Plaintiffs’ facility in Eugene while Nude awaited its licensures from the TTB
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`and the OLCC. Nude and Plaintiffs agreed that, during this time period, Plaintiffs would make
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`available such products to Nude or its designee.
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`15.
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`The MSA further provided that, after Nude obtained its licensures from the TTB
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`and the OLCC, Plaintiffs would provide equipment and services to Nude for the manufacture and
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`packaging of Nude’s beverage products.
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`16.
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`The MSA contained a process by which Nude was to issue purchase orders to
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`Plaintiffs for either co-packing services (prior to licensure) or manufacturing services (following
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`licensure). Plaintiffs and Nude agreed that Plaintiffs could invoice Nude for products delivered
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`or services provided to Nude, and that Nude was responsible for paying such invoices within
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`thirty (30) days. The MSA allowed interest at a rate of 1.5% from the date any invoice was
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`originally issued until paid.
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`Page 3 –COMPLAINT
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`WILDWOOD LAW GROUP LLC
`T: 503.564.3049 | F: 971.347.1425
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`3519 NE 15TH AVE #362
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`PORTLAND, OREGON 97212
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`Case 6:21-cv-01592-MK Document 1 Filed 11/02/21 Page 4 of 13
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`17.
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`The MSA contained other material provisions, including a right for the prevailing
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`party to recover its reasonable attorney fees for any dispute brought pursuant to the MSA. In
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`Section 27 (“Notice”), the parties agreed that any notices required to be given under the MSA be
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`directed to defendant Nude’s principal place of business in Boulder, Colorado, with a copy sent
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`to defendant MXM’s place of business in Vancouver, British Columbia.
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`18.
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`Also on November 19, 2020, Nude and Ninkasi Brewery entered into an
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`Alternating Brewer Proprietorship Agreement, whereby Ninkasi Brewery agreed to provide
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`Nude certain services in support of Nude’s operations (the “Alternating Brewer Agreement”).
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`Pursuant to the Alternating Brewer Agreement, Ninkasi Brewery agreed to periodically alternate
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`its facility in Eugene, including any equipment located at its facility, to allow Nude or Ninkasi to
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`manufacture Nude’s beverage products. Further, Nude agreed to procure and install certain
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`equipment at the facility for the benefit of Nude (and, when not in use by Nude, for use by
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`Ninkasi). The term of the Alternating Brewer Agreement began on November 2, 2020, at which
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`time Nude became obligated to install the identified equipment or, failing that, to terminate the
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`Alternating Brewer Agreement and remit to Ninkasi Brewery the negotiated termination fee.
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`19.
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`Also on November 19, 2020, Plaintiff Ninkasi Brewery and defendant MXM
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`entered into a Guaranty Agreement (the “Guaranty”). Pursuant to the Guaranty, MXM agreed to
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`absolutely and unconditionally guaranty the payment to Ninkasi Brewery of any indebtedness,
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`liabilities or obligations whatsoever owed by Nude to Plaintiffs by virtue of the MSA.
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`20.
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`Also pursuant to the Guaranty, MXM represented and warranted to Ninkasi
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`Brewery that it had reviewed Nude’s financials such that MXM was fully apprised of Nude’s
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`financial condition as of the date of the Guaranty, and that MXM made its own credit analysis of
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`Nude. Further, MXM agreed that Ninkasi Brewery had no obligation to institute suit or exhaust
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`its legal remedies against Nude in order to enforce the Guaranty.
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`21. MXM and Ninkasi Brewery agreed that the Guaranty would be governed by
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`Oregon law and that the prevailing party would be entitled to recover its reasonable attorney fees
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`Page 4 –COMPLAINT
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`WILDWOOD LAW GROUP LLC
`T: 503.564.3049 | F: 971.347.1425
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`3519 NE 15TH AVE #362
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`PORTLAND, OREGON 97212
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`Case 6:21-cv-01592-MK Document 1 Filed 11/02/21 Page 5 of 13
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`and costs in connection with any action under the Guaranty, among other provisions.
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`22.
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`In reliance on the promises in the MSA, the Alternating Brewer Agreement and
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`the Guaranty, including Nude’s agreement to increase production capacity and lengthen the
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`contract term as compared to the provisions in the prior Co-Packing Agreement, Plaintiffs
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`incurred significant costs to purchase and prepare the additional equipment needed to meet
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`Nude’s requested and projected beverage production volumes.
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`23.
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`In addition, Plaintiff Ninkasi Brewery LLC and Nude entered into a Warehousing
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`and Storage Agreement, dated April 12, 2021 (the “Warehousing Agreement”). Pursuant to the
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`Warehousing Agreement, Plaintiffs permitted Nude to store inventory and products in Plaintiffs’
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`warehouse facility, in return for a monthly payment from Nude as calculated under the
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`Warehousing Agreement.
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`24.
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`Following its execution of the MSA and the Alternating Brewer Agreement, Nude
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`issued purchase orders to Plaintiffs. Plaintiffs, in reliance on the promises in the MSA, the
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`Alternating Brewer Agreement, the Warehousing Agreement and the Guaranty, manufactured
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`and packaged beverage products and issued invoices to Nude for its services.
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`25.
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`As of the filing of this complaint, Nude has failed to pay Plaintiffs for amounts
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`due under several invoices issued pursuant to the MSA, the Alternating Brewer Agreement and
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`the Warehousing Agreement, in the total amount of $1,054,486.98. A summary of the unpaid
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`invoices is as follows:
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`(see next page)
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`Page 5 –COMPLAINT
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`WILDWOOD LAW GROUP LLC
`T: 503.564.3049 | F: 971.347.1425
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`3519 NE 15TH AVE #362
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`PORTLAND, OREGON 97212
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`Case 6:21-cv-01592-MK Document 1 Filed 11/02/21 Page 6 of 13
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`Invoice Date
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`3/2/2021
`3/3/2021
`3/18/2021
`3/25/2021
`3/31/2021
`4/3/2021
`4/15/2021
`5/1/2021
`5/30/2021
`6/2/2021
`6/17/2021
`7/1/2021
`7/4/2021
`8/1/2021
`8/7/2021
`8/18/2021
`8/31/2021
`9/1/2021
`9/16/2021
`10/1/2021
`10/21/2021
`11/1/2021
`N/A
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`Invoice Amount
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`$245,862.00
`$6,000.00
`$205.95
`$73,448.34
`$6,000.00
`$30,094.59
`$2,121.18
`$6,000.00
`$315,000.00
`$6,000.00
`$576.15
`$6,000.00
`$98,220.00
`$6,000.00
`$1,407.98
`$8,584.03
`$315,000.00
`$6,000.00
`$8,564.60
`$6,000.00
`$13,649.00
`$6,000.00
`$13,559.60
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`Amount Owing
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`$120,055.56
`$6,000.00
`$205.95
`$73,448.34
`$6,000.00
`$30,094.59
`$2,121.18
`$6,000.00
`$315,000.00
`$6,000.00
`$576.15
`$6,000.00
`$98,220.00
`$6,000.00
`$1,407.98
`$8,584.03
`$315,000.00
`$6,000.00
`$8,564.60
`$6,000.00
`$13,649.00
`$6,000.00
`$13,559.60
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`26.
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`Nude has failed to procure or install the equipment identified under the
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`Alternating Brewer Agreement, and has otherwise failed to pay Ninkasi Brewery a termination
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`fee as required under the Alternating Brewer Agreement.
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`Page 6 –COMPLAINT
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`WILDWOOD LAW GROUP LLC
`T: 503.564.3049 | F: 971.347.1425
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`3519 NE 15TH AVE #362
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`PORTLAND, OREGON 97212
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`Case 6:21-cv-01592-MK Document 1 Filed 11/02/21 Page 7 of 13
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`FIRST CLAIM FOR RELIEF
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`(Breach of Contract)
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` (Count 1 – MSA and Warehousing Agreement)
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`(Against Defendant Nude)
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`27.
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`28.
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`Plaintiffs reallege and incorporate paragraphs 1 through 26 above.
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`Plaintiffs and defendant Nude entered into the MSA and the Warehousing
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`Agreement, which required Nude to pay Plaintiffs for manufacturing, packaging and
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`warehousing services.
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`29.
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`Plaintiffs have performed all obligations required of them pursuant to the MSA
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`and the Warehousing Agreement.
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`30.
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`Nude has breached the MSA and the Warehousing Agreement by failing to pay
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`Plaintiffs $1,054,486.98 for the services performed by Plaintiffs pursuant to the MSA and the
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`Warehousing Agreement.
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`31.
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`Plaintiffs have been injured by Nude’s breaches of the MSA and the Warehousing
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`Agreement.
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`32.
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`Plaintiffs are entitled to an award of damages in the principal amount of
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`$1,054,486.98, plus accrued interest, penalties and other fees, including Plaintiffs’ reasonable
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`attorney fees and costs incurred in connection with this action, all as described under the MSA
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`and the Warehousing Agreement.
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`33.
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`Alternatively, Plaintiffs are entitled to an award of damages in the amount of
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`$2,520,000, representing the agreed-upon termination fee identified in the MSA, plus those
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`damages actually incurred due to Nude’s failure to pay invoices issued pursuant to the
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`Warehousing Agreement, all as to be proven at trial, plus interest, penalties and other fees and
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`Plaintiffs’ attorney fees and costs.
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`Page 7 –COMPLAINT
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`WILDWOOD LAW GROUP LLC
`T: 503.564.3049 | F: 971.347.1425
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`3519 NE 15TH AVE #362
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`PORTLAND, OREGON 97212
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`Case 6:21-cv-01592-MK Document 1 Filed 11/02/21 Page 8 of 13
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`(Count 2 – Alternating Brewer Agreement)
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`(Against Defendant Nude)
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`34.
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`35.
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`Plaintiffs reallege and incorporate paragraphs 1 through 26 above.
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`Plaintiff Ninkasi Brewery and defendant Nude entered into the Alternating
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`Brewer Agreement which required Nude to install certain equipment at Plaintiffs’ facility or pay
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`a termination fee as calculated under the Alternating Brewer Agreement.
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`36.
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`Ninkasi Brewery has performed all obligations required of it pursuant to the
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`Alternating Brewer Agreement.
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`37.
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`Nude has breached the Alternating Brewer Agreement by failing to install the
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`equipment in Plaintiffs’ facility and by failing to pay the termination fee.
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`38.
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`Plaintiffs have been injured by Nude’s breaches of the Alternating Brewer
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`Agreement.
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`39.
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`Ninkasi Brewery is entitled to an award of damages in the principal amount of
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`$2,520,000, representing the agreed-upon termination fee identified in the Alternating Brewer
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`Agreement, plus penalties and other fees.
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`SECOND CLAIM FOR RELIEF
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`(Breach of Duty of Good Faith and Fair Dealing)
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`(Against Defendant Nude)
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`40.
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`41.
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`Plaintiffs reallege and incorporate paragraphs 1 through 26 above.
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`Plaintiffs and Nude entered into the MSA, the Alternating Brewer Agreement and
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`the Warehousing Agreement, each of which is a valid contract.
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`42.
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`Under Oregon law, Nude owed Plaintiffs the duty of good faith and fair dealing as
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`a party to the MSA, the Alternating Brewer Agreement and the Warehousing Agreement because
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`such a duty is implied in every contract.
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`43.
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`Through its conduct, as alleged above, Nude has breached the duty of good faith
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`and fair dealing by undermining the contractual expectations of Plaintiffs, preventing Plaintiffs
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`Page 8 –COMPLAINT
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`WILDWOOD LAW GROUP LLC
`T: 503.564.3049 | F: 971.347.1425
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`3519 NE 15TH AVE #362
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`PORTLAND, OREGON 97212
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`Case 6:21-cv-01592-MK Document 1 Filed 11/02/21 Page 9 of 13
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`from receiving the fruits of the contracts between Plaintiffs and Nude, and acting in Nude’s own
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`self-interest to the determinant of Plaintiffs.
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`44.
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`Plaintiffs have been injured by Nude’s conduct and continue to be injured by its
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`conduct.
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`45.
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`As a direct result of Nude’s actions, Plaintiffs have been damaged in an amount to
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`be proven at trial, but currently believed to be not less than $3,574,486.98.
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`THIRD CLAIM FOR RELIEF
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`(Declaratory Judgment - 28 U.S.C. § 2201, et seq.)
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`(Against Defendant Nude)
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`46.
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`47.
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`Plaintiffs reallege and incorporate paragraphs 1 through 25 above
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`Pursuant to the MSA, Plaintiffs have a right to receive payment from Nude for
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`manufacturing and packaging services provided by Plaintiffs for the benefit of Nude.
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`48.
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`Pursuant to the Alternating Brewer Agreement, Nude has an obligation to install
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`certain equipment at Plaintiffs’ facility or to pay a termination fee, as calculated under the
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`Alternating Brewer Agreement.
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`49.
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`Pursuant to the Warehousing Agreement, Nude has an obligation to pay Plaintiffs
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`for their warehousing services.
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`50.
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`A genuine dispute exists as to the legal rights or obligations of the parties with
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`respect to the MSA, the Alternating Brewer Agreement and the Warehousing Agreement.
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`51.
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`Pursuant to 22 U.S.C. § 2201, Plaintiffs are entitled to a declaration from this
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`Court that Nude has an obligation to pay Plaintiffs for all amounts due under the MSA and the
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`Warehousing Agreement, and that Nude has an obligation to install certain equipment at
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`Plaintiffs facility or pay Plaintiffs a termination fee.
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`Page 9 –COMPLAINT
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`WILDWOOD LAW GROUP LLC
`T: 503.564.3049 | F: 971.347.1425
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`3519 NE 15TH AVE #362
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`PORTLAND, OREGON 97212
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`Case 6:21-cv-01592-MK Document 1 Filed 11/02/21 Page 10 of 13
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`FOURTH CLAIM FOR RELIEF
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`(Quantum Meruit)
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`(Against Defendant Nude)
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`52.
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`53.
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`Plaintiffs reallege and incorporate paragraphs 1 through 25 above.
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`Plaintiffs have conferred a benefit on Nude by manufacturing and packaging
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`beverage products for the benefit of Nude and at Nude’s request.
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`54.
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`55.
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`Plaintiffs have conferred a benefit on Nude by warehousing Nude’s products.
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`Nude was aware of the benefit conferred by Plaintiffs and has retained the benefit
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`conferred pursuant to the rights Nude has under the MSA and the Warehousing Agreement.
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`56.
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`57.
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`Plaintiffs have not been fully compensated for the benefit conferred on Nude.
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`It would be unjust to allow Nude to retain the benefit conferred by Plaintiffs
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`without providing Plaintiffs compensation for the benefit and, therefore, Plaintiffs are entitled to
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`an equitable award of damages reflecting the value of the benefit they conferred upon Nude.
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`FIFTH CLAIM FOR RELIF
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`(Breach of Contract)
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`(Against Defendant MXM)
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`58.
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`59.
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`Plaintiffs reallege and incorporate paragraphs 1 through 25 above.
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`On November 19, 2020, plaintiff Ninkasi Brewery and defendant MXM entered
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`into a Guaranty which obligated MXM to pay for any obligations or liabilities incurred by
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`defendant Nude, including Nude’s obligations under the MSA, the Alternating Brewer
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`Agreement and the Warehousing Agreement.
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`60.
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`Ninkasi Brewery has performed all obligations required of it pursuant to the
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`Guaranty.
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`61. MXM has breached the Guaranty by failing to pay Ninkasi Brewery
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`$1,054,486.98 for the manufacturing, packing and warehousing services performed by Plaintiffs
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`Page 10 –COMPLAINT
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`WILDWOOD LAW GROUP LLC
`T: 503.564.3049 | F: 971.347.1425
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`3519 NE 15TH AVE #362
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`PORTLAND, OREGON 97212
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`Case 6:21-cv-01592-MK Document 1 Filed 11/02/21 Page 11 of 13
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`pursuant to the MSA and the Warehouse Agreement, which is a debt, liability or obligation owed
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`to Plaintiffs by Nude.
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`62. MXM has breached the Guaranty by failing to pay Ninkasi Brewery $2,520,000
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`for the termination fee to which Nude is obligated to pay Ninkasi Brewery under the Alternating
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`Brewer Agreement.
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`63.
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`64.
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`Ninkasi Brewery has been injured by MXM’s breaches of the Guaranty.
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`Ninkasi Brewery is entitled to an award of damages in in an amount to be proven
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`at trial, but currently believed to be not less than $3,574,486.98.
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`65.
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`Pursuant to the Guaranty, Ninkasi Brewery is entitled to an award of its
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`reasonable costs and attorney fees.
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`SIXTH CLAIM FOR RELIF
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`(Breach of Duty of Good Faith and Fair Dealing)
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`(Against Defendant MXM)
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`66.
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`67.
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`valid contract.
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`Plaintiffs reallege and incorporate paragraphs 1 through 25 above.
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`Plaintiff Ninkasi Brewery, LLC and MXM entered into the Guaranty, which is a
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`68.
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`Under Oregon law, MXM owed Ninkasi Brewery the duty of good faith and fair
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`dealing as a party to the Guaranty, because such a duty is implied in every contract.
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`69.
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`Through its conduct, as alleged above, MXM has breached the duty of good faith
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`and fair dealing by undermining the contractual expectations of Ninkasi Brewery, preventing
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`Ninkasi Brewery from receiving the fruits of the Guaranty, and acting in MXM’s own self-
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`interest to the determinant of Ninkasi Brewery.
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`70.
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`Ninkasi Brewery has been injured by MXM’s conduct and continues to be
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`injured by its conduct.
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`71.
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`As a direct result of MXM’s actions, Ninkasi Brewery has been damaged in an
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`amount to be proven at trial, but currently believed to be not less than $3,574,486.98.
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`Page 11 –COMPLAINT
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`WILDWOOD LAW GROUP LLC
`T: 503.564.3049 | F: 971.347.1425
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`3519 NE 15TH AVE #362
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`PORTLAND, OREGON 97212
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`Case 6:21-cv-01592-MK Document 1 Filed 11/02/21 Page 12 of 13
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`SEVENTH CLAIM FOR RELIEF
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`(Declaratory Judgment – 22 U.S.C. § 2201, et seq.)
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`(Against Defendant MXM)
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`72.
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`73.
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`Plaintiffs reallege and incorporate paragraphs 1 through 25 above.
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`Pursuant to the Guaranty, Ninkasi Brewery has a right to receive payment from
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`MXM for any debts, obligations or liabilities owed to Ninkasi Brewery by Nude.
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`74.
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`A genuine dispute exists as to the legal rights or obligations of the parties with
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`respect to the Guaranty.
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`75.
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`Pursuant to 22 U.S.C. § 2201, Ninkasi Brewery is entitled to a declaration from
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`this Court that MXM has an obligation to pay Ninkasi Brewery for all amounts owed by Nude
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`due under the MSA, the Alternating Brewer Agreement and the Warehousing Agreement.
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`DEMAND FOR JURY TRIAL
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`76.
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`Pursuant to Fed. R. Civ. P. 38, Plaintiffs hereby demand a jury trial.
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`WHEREFORE, Plaintiffs respectfully request the Court enter a judgment in their favor as
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`follows:
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`1.
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`On their First Claim for Relief, Count 1, for a judgment against defendant Nude in
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`the amount of $1,054,486.98, plus pre-judgment interest, and an award of reasonable attorney
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`fees and costs;
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`2.
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`On their First Claim for Relief, Count 2, for a judgment against defendant Nude
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`requiring it to install certain equipment in Plaintiffs facility or, alternatively, to pay the
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`termination fee under the Alternating Brewer Agreement, in the amount of $2,520,000;
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`3.
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`On their Second Claim for Relief, for a judgment against Nude in an amount to be
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`proven at trial, but currently believed to be not less than $3,574,486.98;
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`4.
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`On their Third Claim for Relief, for a judgment declaring that Nude owes
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`Plaintiffs certain obligations under its contracts with Plaintiffs, including that Nude owes
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`Plaintiffs certain amounts due under the contracts;
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`Page 12 –COMPLAINT
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`WILDWOOD LAW GROUP LLC
`T: 503.564.3049 | F: 971.347.1425
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`3519 NE 15TH AVE #362
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`PORTLAND, OREGON 97212
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`Case 6:21-cv-01592-MK Document 1 Filed 11/02/21 Page 13 of 13
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`5.
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`On their Fourth Claim for Relief, for a judgment against Nude in the equitable
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`amount reflecting the benefit Plaintiffs conferred upon Nude without compensation;
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`6.
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`On their Fifth Claim for Relief, for a judgment against MXM in the amount of
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`$3,574,486.98, plus pre-judgment interest, and award of Plaintiffs’ reasonable attorney fees and
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`costs;
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`7.
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`On their Sixth Claim for Relief, for a judgment against MXM in an amount to be
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`proven at trial, but currently believed to be not less than $3,574,486.98;
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`8.
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`On their Seventh Claim for Relief, for a judgment declaring that MXM owes
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`Plaintiff Ninkasi Brewery certain obligations under its contract with Ninkasi Brewery
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`9.
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`10.
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`For post-judgment interest at the statutory rate, until fully paid; and
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`For such other relief as the Court deems proper.
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`DATED this 2nd day of November, 2021.
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`WILDWOOD LAW GROUP LLC
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`/s/ Nicholas A. Kampars
`By
` Nicholas A. Kampars, OSB No. 063870
`nick.kampars@wildwoodlaw.com
`3519 NE 15th Avenue, #362
`Portland, Oregon 97212
`Telephone: (503) 564-3049
`Fax: (971) 347-1425
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`Of Attorneys for Plaintiffs
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`Page 13 –COMPLAINT
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`WILDWOOD LAW GROUP LLC
`T: 503.564.3049 | F: 971.347.1425
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`3519 NE 15TH AVE #362
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`PORTLAND, OREGON 97212
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