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`
`TULALIP TRIBAL FEDERAL
`CORPORATION,
`
`
`v.
`
`THE BOARD OF TRUSTEES OF THE
`LELAND STANFORD JUNIOR
`UNIVERSITY,
`
`
`
`Plaintiff,
`
`Defendant.
`
`
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`
`
`Case 2:21-cv-01345-RAJ Document 1 Filed 10/01/21 Page 1 of 12
`
`
`
`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF WASHINGTON
`AT SEATTLE
`
` Case No.
`
`COMPLAINT FOR BREACH OF
`CONTRACT AND VIOLATION OF
`COVENANT OF GOOD FAITH AND
`FAIR DEALING
`
`
`DEMAND FOR JURY TRIAL
`
`
`
`Plaintiff Tulalip Tribal Federal Corporation (“TTFC”) alleges the following causes of
`action against Defendant The Board Of Trustees Of The Leland Stanford Junior University
`(“Stanford”).
`
`I. INTRODUCTION
`The United States is experiencing the worst man-made epidemic in modern medical
`1.
`history—the misuse, abuse, and over-prescription of opioids.
`From 1999 to 2019, nearly 500,000 Americans lost their lives to an opioid
`2.
`overdose, more than eight times as many American lives as were lost in the entire Vietnam War.
`
`
`COMPLAINT FOR BREACH OF CONTRACT AND
`BREACH OF IMPLIED COVENANT OF GOOD
`FAITH AND FAIR DEALING - 1
`
`128096.0014/8616308.16
`
`LANE POWELL PC
`1420 FIFTH AVENUE, SUITE 4200
`P.O. BOX 91302
`SEATTLE, WASHINGTON 98111-9402
`206.223.7000 FAX: 206.223.7107
`
`

`

`Case 2:21-cv-01345-RAJ Document 1 Filed 10/01/21 Page 2 of 12
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`Native Americans have been particularly devastated by this crisis. According to
`3.
`the Centers for Disease Control and Prevention (“CDC”), by 2014, Native Americans had the
`highest death rate from opioid overdose of any demographic group in the United States.1
`
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`Opioids have reshaped daily reality for the Tulalip Tribes (defined herein) in
`4.
`numerous ways, including increased and intensified emergency responses to overdoses; increased
`drug-related offenses affecting the victims of those crimes and the criminal justice system as a
`whole; additional resources spent on community and social programs; loss of workplace
`productivity due to opioid addiction among employees; higher worker’s compensation costs due
`to opioid-related claims; and prevalent opioid abuse throughout the Tulalip Reservation which has
`caused a strain on the emotional, physical, and spiritual health of the community.
`To protect the tribal community’s welfare and continued sovereignty, the Tulalip
`5.
`Tribes have been working to confront the epidemic in a variety of ways. The Tribes spend
`substantial amounts of its budget and allocates significant resources on mitigation and treatment
`programs, social services, as well as criminal justice services.
`But while the Tulalip Tribes has committed considerable resources to fight the
`6.
`opioid crisis, the Tulalip Tribes realizes fully addressing the crisis also requires discovering and
`
`
`1 Dan Nolan and Chris Amico, How Bad
`the Opioid Epidemic?, Frontline (Feb. 23, 2016),
`is
`https://www.pbs.org/wgbh/frontline/article/how-bad-is-the-opioid-epidemic/ (headings revised for clarity).
`
`COMPLAINT FOR BREACH OF CONTRACT AND
`BREACH OF IMPLIED COVENANT OF GOOD
`FAITH AND FAIR DEALING - 2
`
`128096.0014/8616308.16
`
`LANE POWELL PC
`1420 FIFTH AVENUE, SUITE 4200
`P.O. BOX 91302
`SEATTLE, WASHINGTON 98111-9402
`206.223.7000 FAX: 206.223.7107
`
`

`

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`Case 2:21-cv-01345-RAJ Document 1 Filed 10/01/21 Page 3 of 12
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`
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`developing an actual medicine to treat opioid addiction and so it sought out and provided funding
`to a major research university to discover and develop a drug to treat opioid addiction.
`To that end, TTFC executed an agreement through which TTFC shared its
`7.
`confidential research information and proprietary data with Stanford’s Behavioral and Functional
`Neuroscience Laboratory in the hopes of developing a cure and patenting it under TTFC’s name.
`For its part, Stanford expressly promised to disclose the results of the research that used TTFC’s
`confidential information and proprietary data.
`After the research yielded promising and patentable results for treating opioid
`8.
`addiction with an isolated fraction of natural cannabinoid oil extract, Stanford promptly broke their
`promise. Based on information and belief, Stanford secretly duplicated TTFC’s patentable, natural
`isolated fraction and applied for a provisional patent for a synthetic version. Because this synthetic
`version derived from research that used TTFC’s confidential information, proprietary data, and
`monies, it is the intellectual property of TTFC.
`Further, Stanford’s refusal to disclose its synthetic provisional patent application to
`9.
`TTFC constitutes a material breach of its promise to disclose all results of the research that derived
`from TTFC’s confidential information, proprietary data, and monies.
`TTFC therefore brings this action to hold Stanford accountable for its breach of
`10.
`contract, protect the value of TTFC’s confidential information and proprietary data, and ensure
`that the goal of producing a cure for the opioid crisis has not been subverted.
`
`A.
`
`II. PARTIES
`Tulalip Tribal Federal Corporation.
`Plaintiff Tulalip Tribal Federal Corporation (“TTFC”) is a Tribal business
`11.
`corporation authorized under Section 17 of the Indian Reorganization Act of June 18, 1934 as
`amended (now codified at 25 U.S.C. § 477 as amended). TTFC is wholly owned by the Tulalip
`Tribes and is the successor in interest to Tribal Economic Development Corporation, a Tribal
`business organized, chartered and wholly-owned by the Tulalip Tribes and established pursuant to
`
`
`COMPLAINT FOR BREACH OF CONTRACT AND
`BREACH OF IMPLIED COVENANT OF GOOD
`FAITH AND FAIR DEALING - 3
`
`128096.0014/8616308.16
`
`LANE POWELL PC
`1420 FIFTH AVENUE, SUITE 4200
`P.O. BOX 91302
`SEATTLE, WASHINGTON 98111-9402
`206.223.7000 FAX: 206.223.7107
`
`

`

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`Case 2:21-cv-01345-RAJ Document 1 Filed 10/01/21 Page 4 of 12
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`the Constitution of the Tulalip Tribes of the Tulalip Reservation, Washington, and pursuant to
`Tribal law, Tulalip Tribal Code Chapter 15.05. TTFC’s registered address is at 8802 27th Avenue
`NE, Quil Ceda Village, Washington.
`
`B.
`
`Stanford.
`The Board of Trustees of the Leland Stanford Junior University (“Stanford”) are
`12.
`trustees of a trust with corporate powers under California law. Cal. Educ. Code § 94000. Stanford
`is located at 3000 El Camino Real, Suite 300, Palo Alto, California 94306.
`
`III. JURISDICTION AND VENUE
`This Court has subject matter jurisdiction over this action because the amount in
`13.
`controversy exceeds $75,000 and the parties are citizens of different states. Specifically, TTFC
`seeks to recover monetary damages in an amount to be determined at trial, but no less than $76,000.
`This Court has personal jurisdiction over Stanford because Stanford purposefully
`14.
`availed itself of the privilege of doing business in this District. Stanford entered into multiple,
`multi-year contracts with TTFC, and Stanford knew TTFC resided and transacted business in the
`state of Washington. Stanford reached into Washington to create continuing relationships and
`obligations with a resident of the forum and the forum itself. These continuing relationships with
`Washington are evidenced by the extensive communications Stanford has had (and continues to
`have) with TTFC’s Washington-based agents over multiple years. Thus, Stanford specifically
`invoked the benefits and protections of Washington and must therefore submit to the forum’s
`jurisdiction in return.
`Venue is proper in this district because a substantial part of the events giving rise
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`to TTFC’s claims occurred in this District including, but not limited to, Stanford’s in-person visits
`and presentations to the Tulalip Tribes on the Tulalip Reservation.
`
`IV. BACKGROUND FACTS
`It is well established that the United States faces an increasingly grave problem:
`16.
`the misuse, abuse, and over-prescription of opioids. Much like other sovereign Indian nations,
`
`
`COMPLAINT FOR BREACH OF CONTRACT AND
`BREACH OF IMPLIED COVENANT OF GOOD
`FAITH AND FAIR DEALING - 4
`
`128096.0014/8616308.16
`
`LANE POWELL PC
`1420 FIFTH AVENUE, SUITE 4200
`P.O. BOX 91302
`SEATTLE, WASHINGTON 98111-9402
`206.223.7000 FAX: 206.223.7107
`
`

`

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`Case 2:21-cv-01345-RAJ Document 1 Filed 10/01/21 Page 5 of 12
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`the Tulalip Tribes has suffered profound consequences of the opioid epidemic. The effects of
`the opioid epidemic on the Tulalip Tribes cannot be overstated. Tulalip Enrollment Department
`records reflect
`that, since 2006, opioids caused the deaths of at least fifty-eight enrolled
`members. Further, the overdose death rate for Native Americans is six times higher than it is
`for the white population in Snohomish County.2
`Since as early as 2006, the Tulalip Tribes have been interested in finding a workable
`17.
`solution to treating opioid addiction. This problem is twofold for TTFC insofar as tribal members
`suffer a high rate of opioid and heroin addiction, far above the statistical norm in the United States.3
`TTFC has recognized that a cannabis-based solution might not only help tribal members but could
`also address the global opioid epidemic, thus providing a morally, as well as financially, rewarding
`source of income, through commercialization of such a solution.
`On May 1, 2018, Stanford, on behalf of Stanford’s Behavioral and Functional
`18.
`Neuroscience Laboratory Service Center (the “Stanford Center”), entered into and signed a
`Confidential Service Center Agreement: Academic and Other Non-Profit Institutions, dated
`May 1, 2018, by and between the various Stanford University parties and the Tribal Economic
`Development Corporation (the “Service Center Agreement”). Director/Professor Mehrdad
`Shamloo executed the Service Center Agreement on behalf of the Stanford Center.
`On page 5 of the document, entitled “Scope of Work,” the study was entitled
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`“Evaluation of cannabis oil therapeutic effects in opioid addiction and Alzheimer’s disease.” The
`“Statement of Purpose” in the Service Center Agreement states that the overall goal of the project
`is to study the efficacy of two novel medical cannabinoid flower extracts to: (i) obviate or treat
`opioid dependence in a rat model of addiction, (ii) to improve the cognitive function and to reverse
`
`
`2 https://www.snohd.org/DocumentCenter/View/648/Heroin-in-Snohomish-County-Mortality-and-Treatment-Trends-for-
`2015-PDF at 7.
`3 According to the Centers for Disease Control and Prevention, Native Americans experienced the largest increase in
`drug and opioid-involved overdose mortality rates compared with other racial/ethnic groups. Sujata Joshi et al, Drug,
`Opioid-Involved, and Heroin-Involved Overdose Deaths Among American Indians and Alaska Natives — Washington,
`1999–2015 (December 21, 2018) https://www.cdc.gov/mmwr/volumes/67/wr/mm6750a2.htm.
`
`
`COMPLAINT FOR BREACH OF CONTRACT AND
`BREACH OF IMPLIED COVENANT OF GOOD
`FAITH AND FAIR DEALING - 5
`
`128096.0014/8616308.16
`
`LANE POWELL PC
`1420 FIFTH AVENUE, SUITE 4200
`P.O. BOX 91302
`SEATTLE, WASHINGTON 98111-9402
`206.223.7000 FAX: 206.223.7107
`
`

`

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`Case 2:21-cv-01345-RAJ Document 1 Filed 10/01/21 Page 6 of 12
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`or prevent the pathological progression of the pathological malformation associated with
`Alzheimer’s disease; and (iii) regulate the expression of the cathelicidin gene (CAMP). The
`“Statement of Purpose” goes on to state that if there is evidence that cannabis oil extracts can
`achieve these earlier mentioned objectives, then further research would attempt to isolate the
`specific cannabinoids or terpenes and TTFC would pursue a patent for the isolated portion.
`In the “Background” statement for the project, the Service Center Agreement
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`provides that the research takes a “novel approach” to test the hypothesis that certain cannabinoids
`and/or terpenes—that may or may not include CBD or THC—may stimulate pathways of interest,
`particularly the cathelicidin gene pathway.4 This is the brain pathway affected by Alzheimer’s
`disease and may also provide a “novel approach” to determine why cannabis is so broad in its
`apparent health benefits to humans, including a possible solution to opioid and heroin addiction.
`Exhibit A of the Service Center Agreement shows that TTFC would pay
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`approximately $2,000,000 for the completed study, which was expected to take about thirty (30)
`months. As of the date of this Complaint, TTFC has paid $3,195,623.86 to fund this research
`study.
`
`Various sections of the Service Center Agreement provide that TTFC owns the
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`results of the research, including the “Research Material” (Section 1), all confidential material
`(Section 3), the “Services Data” (i.e., data generated as a result of Stanford’s research) (Section
`10) and any inventions resulting from the services and relying on the “Research Material” provided
`by TTFC under the agreement (Section 11). Stanford also agreed that it would promptly disclose
`all such inventions and assign to TTFC all of the related ownership rights.
`The Service Center Agreement was amended twice. Under the “First Amendment,”
`23.
`dated December 10, 2019, TTFC provided an additional $900,000 so that Stanford could continue
`to pursue “Fractionation of Cannabis Oil to Find Novel Patentable HPLC Fraction That Treats
`
`
`4 Cathelicidin antimicrobial peptides (CAMP) are polypeptides that, essentially, help the body fight off infections and
`various pathogens.
`
`
`COMPLAINT FOR BREACH OF CONTRACT AND
`BREACH OF IMPLIED COVENANT OF GOOD
`FAITH AND FAIR DEALING - 6
`
`128096.0014/8616308.16
`
`LANE POWELL PC
`1420 FIFTH AVENUE, SUITE 4200
`P.O. BOX 91302
`SEATTLE, WASHINGTON 98111-9402
`206.223.7000 FAX: 206.223.7107
`
`

`

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`Case 2:21-cv-01345-RAJ Document 1 Filed 10/01/21 Page 7 of 12
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`Opioid Addiction.” On page 3 of the First Amendment, Stanford promised to use the additional
`monies provided by TTFC to purchase supplies and equipment to perform its research. Under the
`heading “AIM 1,” the First Amendment states that researchers will use high performance liquid
`chromatography or “HPLC” to fractionate the cannabis extract. The preparative HPLC isolated
`the most efficacious part of the whole cannabis plant extract—the THC-rich fraction of the oil (the
`“THC-rich fraction”).
`The Second Amendment to the Service Center Agreement, dated November 30,
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`2020, extended the cannabinoid treatment study until September 30, 2021. The Second
`Amendment continued the research using HPLC to fractionate cannabis extract, Pharmacokinetic,
`Pharmacodynamics, and Safety profiles of THC-rich and remainder fraction, and using THC-rich
`fraction as anti-inflammatory treatments under the study titled, “Evaluation of cannabis oil
`therapeutic effects in opioid addiction and Alzheimer’s disease” pursuant to the First Amendment
`to the Service Center Agreement. There were no additional costs or expenses incurred under this
`Second Amendment and “All other terms and conditions of the [Service Center] Agreement and
`First Amendment remain unchanged.” TTFC subsequently gave Stanford a “gift” of money
`pursuant to a Condition of Gift Award in Support of Stanford Faculty in the amount of $75,000.00.
`The purpose of the gift was to support Professor Annelise Barron in Stanford’s Department of
`Bioengineering for her laboratory’s general research efforts.
`TTFC then gave Stanford three additional separate “gifts” of money in the amount
`25.
`of $75,000.00 each—with a cumulative total of $225,000.00. The purpose of these gifts was to
`support Professor Annelise Barron in Stanford’s Department of Bioengineering for her
`laboratory’s general research efforts. All of the “gift” arrangements provided that the use of these
`subsequent gifts award did not supersede any prior agreements between Stanford and TTFC,
`especially the parties’ rights and obligations under the Service Center Agreement.
`Based on the foregoing, TTFC discovered that Stanford’s principal investigators
`26.
`filed a patent application (without notifying TTFC) for inventions that, based on information and
`
`
`COMPLAINT FOR BREACH OF CONTRACT AND
`BREACH OF IMPLIED COVENANT OF GOOD
`FAITH AND FAIR DEALING - 7
`
`128096.0014/8616308.16
`
`LANE POWELL PC
`1420 FIFTH AVENUE, SUITE 4200
`P.O. BOX 91302
`SEATTLE, WASHINGTON 98111-9402
`206.223.7000 FAX: 206.223.7107
`
`

`

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`Case 2:21-cv-01345-RAJ Document 1 Filed 10/01/21 Page 8 of 12
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`belief, rely on TTFC’s confidential information and proprietary data. On June 11, 2021,
`representatives from TTFC and Stanford participated in a Zoom call to discuss the research
`progress and delivery of the final report detailing the patentable results of the TTFC-funded
`research. In attendance on behalf of Stanford were Professors Annelise Barron and Mehrdad
`Shamloo. During the call, Professor Mehrdad Shamloo disclosed that he wanted to focus on
`creating a small molecule with THC to treat addiction and derive a small molecule drug. Professor
`Shamloo then added that Stanford’s research could support two patents: a TTFC patent focusing
`on the unique extraction process; and a provisional patent on a small molecule with a similar
`profile.
`After some additional discussion, Professor Shamloo and Professor Annelise
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`Barron went on to state that they had already created a small molecule that mimics the THC
`fractionate and, as a result, they had filed a provisional patent application covering the small
`molecule subject matter. During the discussion, Professor Shamloo seemed nervous about
`disclosing this matter. Professor Shamloo offered to show TTFC the small molecule research, but
`only if TTFC signed a non-disclosure agreement.
`Before TTFC could formally respond during the video call, Professor Shamloo
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`proceeded to put the slides onto the shared screen, on Zoom, detailing the small molecule
`development and explaining Stanford’s process for filing what Stanford represented to be a
`separate provisional patent application. Professor Barron noted that the subject matter of
`Stanford’s provisional patent application was not covered by its research for TTFC. Professor
`Barron insisted that Stanford had acted properly. Based on the materials shown on the Zoom call
`and the explanations provided by Professor Shamloo and Professor Barron, TTFC realized that
`Stanford had chemically synthesized an analogue to the extraction derived from TTFC’s
`confidential information, equipment, and funding, and filed a provisional patent application on
`that basis.
`
`
`COMPLAINT FOR BREACH OF CONTRACT AND
`BREACH OF IMPLIED COVENANT OF GOOD
`FAITH AND FAIR DEALING - 8
`
`128096.0014/8616308.16
`
`LANE POWELL PC
`1420 FIFTH AVENUE, SUITE 4200
`P.O. BOX 91302
`SEATTLE, WASHINGTON 98111-9402
`206.223.7000 FAX: 206.223.7107
`
`

`

`Case 2:21-cv-01345-RAJ Document 1 Filed 10/01/21 Page 9 of 12
`
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`Soon thereafter, TTFC sent Stanford a letter on June 25, 2021, requesting that
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`Stanford provide for review (1) all of the Services Data under Section 10 of the Service Center
`Agreement; (2) all patent applications relating to the Service Center Agreement; (3) all papers filed
`with any patent receiving office; and (4) any grant applications related to the subject matter of the
`Service Center Agreement.
`On July 14, 2021, Stanford formally acknowledged that it had filed a patent
`30.
`application but refused to provide TTFC any of the requested documents and information. Instead,
`Stanford disclaimed any obligation to disclose the requested Services Data, patent and grant
`applications, and related documents because Stanford’s provisional patent application allegedly
`was limited to “synthetic chemical compounds” that purportedly did not rely on TTFC’s
`confidential information or use monies provided by TTFC to Stanford.
`Stanford’s excuse rings hollow. Indeed, Stanford has embarked on a strategy to
`31.
`appropriate and commercialize intellectual property that belongs to TTFC under the Service Center
`Agreement, including data, research results, trade secrets, confidential information and potentially
`patentable subject matter. Stanford has also used equipment and materials it purchased using
`monies provided to it by TTFC to pursue these ends. Further, Stanford has refused to disclose to
`TTFC the inventions it conceived or reduced to practice using and relying on the confidential
`information TTFC conveyed to Stanford.
`If Stanford’s hands were clean, Stanford would have responded to the TTFC
`32.
`demand letter in a more forthcoming manner. For example, Stanford could have easily disclosed
`to TTFC the contents of its “synthetic” provisional patent application, subject to a nondisclosure
`agreement. It also could have provided TTFC with incontrovertible documentation that evidenced
`the alleged separation of its “synthetic” provisional patent application from the “natural extract
`fractionates” patent application Stanford expects TTFC to file. Stanford did not choose the
`forthcoming approach. Instead, using monies and confidential information it received from TTFC,
`Stanford applied for a provisional patent application with the likely outcome that Stanford will
`
`
`COMPLAINT FOR BREACH OF CONTRACT AND
`BREACH OF IMPLIED COVENANT OF GOOD
`FAITH AND FAIR DEALING - 9
`
`128096.0014/8616308.16
`
`LANE POWELL PC
`1420 FIFTH AVENUE, SUITE 4200
`P.O. BOX 91302
`SEATTLE, WASHINGTON 98111-9402
`206.223.7000 FAX: 206.223.7107
`
`

`

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`Case 2:21-cv-01345-RAJ Document 1 Filed 10/01/21 Page 10 of 12
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`commercialize the inventions derived from TTFC’s confidential information and proprietary data
`to enrich itself.
`
`V. CAUSES OF ACTION
`First Cause of Action—Breach of Contract
`TTFC incorporates herein by reference the allegations in paragraphs 1-32.
`33.
`TTFC has performed its obligations and met all conditions precedent under the
`34.
`Service Center Agreement.
`This Service Center Agreement requires Stanford to disclose to TTFC all of the
`35.
`inventions and data derived from TTFC’s confidential information and/or monies provided by
`TTFC to Stanford. On information and belief, Stanford’s synthetic provisional patent application
`is based on inventions derived from TTFC’s confidential information, proprietary data, and from
`monies provided by TTFC to Stanford, under the Service Center Agreement.
`Stanford’s failure to disclose its provisional patent application is therefore a
`36.
`material breach of the Service Center Agreement.
`As a direct and proximate result of this breach of contract, TTFC has been damaged
`37.
`in an amount to be determined at trial.
`
`Second Cause of Action—Breach of Covenant of Good Faith and Fair Dealing
`TTFC incorporates herein by reference the allegations in paragraphs 1-37.
`38.
`39.
`The Service Center Agreement contained an implied covenant that imposes on each
`party a duty of good faith and fair dealing.
`The agreed-upon purpose of the Service Center Agreement was that, in exchange
`40.
`for the monies given to Stanford by TTFC, TTFC would receive all of the tangible benefits that
`resulted from Stanford’s research under the Service Center Agreement.
`By surreptitiously filing a provisional patent application based on inventions
`41.
`derived from TTFC’s confidential information, proprietary data, and, monies provided by TTFC,
`Stanford unfairly frustrated and undermined the TTFC’s reasonable expectations, thereby
`
`
`COMPLAINT FOR BREACH OF CONTRACT AND
`BREACH OF IMPLIED COVENANT OF GOOD
`FAITH AND FAIR DEALING - 10
`
`128096.0014/8616308.16
`
`LANE POWELL PC
`1420 FIFTH AVENUE, SUITE 4200
`P.O. BOX 91302
`SEATTLE, WASHINGTON 98111-9402
`206.223.7000 FAX: 206.223.7107
`
`

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`Case 2:21-cv-01345-RAJ Document 1 Filed 10/01/21 Page 11 of 12
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`depriving TTFC of the benefits of the Service Center Agreement. Stanford’s actions therefore
`breached the Service Center Agreement’s covenant of good faith and fair dealing.
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`VI. PRAYER FOR RELIEF
`TTFC requests the following alternative and cumulative relief:
`That Stanford be preliminarily and permanently enjoined and restrained from
`1.
`directly or indirectly making, using, importing, exporting, offering for sale, or selling anything
`related to TTFC’s confidential information, including data arising from or relating to the research
`performed by Stanford for TTFC;
`That the Court order Stanford to disclose its provisional patent application, and
`2.
`related, supporting materials for said application, to TTFC;
`A declaratory judgment by this Court ordering Stanford to assign all its right, title
`3.
`and interest in the inventions reflected in its provisional patent application to TTFC;
`That Stanford pay damages adequate to compensate TTFC for the breach of
`4.
`contract and breach of good faith claims in excess of $75,000;
`That TTFC be awarded prejudgment interest, post-judgment interest, and costs;
`5.
`6.
`That the Court order Stanford to refrain from disclosing or filing additional patent
`applications on TTFC’s confidential information, including data arising from or relating to the
`research performed by Stanford for TTFC; and
`Such other and further relief as the Court may deem just and proper.
`7.
`
`
`COMPLAINT FOR BREACH OF CONTRACT AND
`BREACH OF IMPLIED COVENANT OF GOOD
`FAITH AND FAIR DEALING - 11
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`128096.0014/8616308.16
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`LANE POWELL PC
`1420 FIFTH AVENUE, SUITE 4200
`P.O. BOX 91302
`SEATTLE, WASHINGTON 98111-9402
`206.223.7000 FAX: 206.223.7107
`
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`Case 2:21-cv-01345-RAJ Document 1 Filed 10/01/21 Page 12 of 12
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`VII. JURY TRIAL DEMAND
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`Plaintiff demands a trial by jury on all claims and of all issues so triable.
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`DATED: October 1, 2021
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`LANE POWELL PC
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`By:
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` s/Steven B. Winters
`Steven B. Winters, WSBA No. 22393
`Kenneth R. Davis II, WSBA No. 21928
`Telephone: 206.223.7000
`winterss@lanepowell.com
`davisk@lanepowell.com
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`Attorneys for Tulalip Tribal Federal Corporation
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`COMPLAINT FOR BREACH OF CONTRACT AND
`BREACH OF IMPLIED COVENANT OF GOOD
`FAITH AND FAIR DEALING - 12
`
`128096.0014/8616308.16
`
`LANE POWELL PC
`1420 FIFTH AVENUE, SUITE 4200
`P.O. BOX 91302
`SEATTLE, WASHINGTON 98111-9402
`206.223.7000 FAX: 206.223.7107
`
`