1 IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
FOR BENTON COUNTY
2
3 SCOTT BRUNDRIDGE, DONALD HODGIN,
4 JESSIE JAMES, CLYDE KILLEN, PEDRO
NICACIO, SHANE O'LEARY, RAYMOND Case No. 99-2-01250-7
5 RICHARSON, JAMES STULL, RANDALL
WALLI, AND DAVID FAUBION,
6
Plaintiffs,
7 FIRST AMENDED COMPLAINT FOR
DAMAGES AND DEMAND FOR
8 vs. JURY TRIAL
9 FLUOR DANIEL, INC., a California
Corporation, FLUOR DANIEL HANFORD,
10 INC., a Washington Corporation, FLUOR
DANIEL NORTHWEST, INC., a Washington
11 Corporation, JERRY NICHOLS, an individual
12 and his marital community, DAVID
FOUCAULT, an individual and his marital
13 community, AND JIM HOLLADAY, an
individual and his marital community,
14
Defendants.
15
16 I. PARTIES, JURISDICTION, AND VENUE
17 1.1 Plaintiff Scott Brundridge is a citizen of the State of Washington residing in the
18
of Benton.
19
1.2 Plaintiff Donald Hodgin is a citizen of the State of Washington residing in the
20
21 Benton.
22 1.3 Plaintiff Jessie James is a citizen of the State of Washington residing in the county
23 Benton.
24 1.4 Plaintiff Clyde Killen is a citizen of the State of Washington residing in the county
25 Benton.
FIRST AMENDED COMPLAINT FOR DAMAGES GOVERNMENT ACCOUNTABILITY PROJECT
AND DEMAND FOR JURY TRIAL 1402 THIRD AVE., SUITE
Page 1 of 8 SEATTLE, WA 98101
TEL: (206)
SNIPPETS:
JESSIE JAMES, CLYDE KILLEN, PEDRO
FLUOR DANIEL, INC., a California Corporation, FLUOR DANIEL HANFORD,
10 INC., a Washington Corporation, FLUOR DANIEL NORTHWEST, INC., a Washington
17 1.1 Plaintiff Scott Brundridge is a citizen of the State of Washington residing in the
of Benton.
Defendant Fluor Daniel, Inc. is incorporated in California doing business in
FDH is a wholly owned subsidiary of FD.
Hanford was previously a nuclear weapons production
1.13 Defendant David Foucault is a citizen of Washington state and a resident of Benton
County containing a marital community.
employed by FDNW as Construction Director.
1.14 Defendant Jim Holladay is a citizen of Washington state and a resident of Franklin
1.15 Defendant Jerry Nichols is a citizen of Washington state and a resident of Benton
11 1.16 All acts and omissions alleged herein occurred in Benton County.
16 2.1 The plaintiffs herein are union pipefitters who worked at Flour Daniel Northwest at
18 pipefitters at Hanford frequently work without layoff for many years as opposed to other
24 FDNW management to install a valve in a line that would carry high level nuclear waste.
10 2.4 Subsequent to their wrongful terminations, the Pipefitters I group filed administrative
15 2.5 At work, Plaintiffs Richardson, James, Hodgin, and Brundridge (hereinafter referred to
19 against the wrongful terminations as being linked to reporting safety violations.
qualified are to be laid off first.
23 retaliating against them for their whistleblowing activities and/or for supporting
2.14 FDH, Foucault, Holladay and Nichols participated in the layoff of Pipefitters III. 4
FDNW managers wrongfully terminated Dave Faubion for supporting the return to
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