IN THE CIRCUIT COURT OF THE STATE OF OREGON

FOR COUNTY OF JOSEPHINE

EDWARD SNOOK,
Plaintiff,
No. 14CV0835

DEBORAH SWAN,
Defendant

LIMITED DISCOVERY REQUEST

AFFIDAVIT IN SUPPORT OF
MOTION, AND ORDER FOR COMMISSION TO TAKE
TELEPHONIC OUT-OF-STATE DEPOSITION

I, Deborah Swan, who is representing myself, state it is necessary to allow limited

discovery in the above-entitled case, in order to take telephonic depositions of Janet
Dyer and Charles Dyer, located in the state of Oklahoma.
I hereby declare that the above statement is true to the best of my knowledge and belief,
this discovery request is being made in good faith, and that I understand it is made for use
as evidence in court and is subject to penalty for perjury.
Date 02/12/2015
/s/ Deborah Kay Swan

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IN THE CIRCUIT COURT OF THE STATE OF OREGON

FOR COUNTY OF JOSEPHINE
EDWARD SNOOK,
Plaintiff,
No. 14CV0835

DEBORAH SWAN,
Defendant

MOTION FOR LIMITED DISCOVERY AND COMMISSION TO TAKE

OUT-OF-STATE TELEPHONIC DEPOSITION

Pursuant to ORCP 38 and based on the above affidavit, I, Deborah Swan, Defendant,
moves this court for limited discovery, and for an order issuing a commission for
depositions to be taken by telephone, for 2 witnesses located in the state of Oklahoma,
and that the commission be effective for 30 day(s) from the date of signing by the clerk.

Dated this 12th day of February, 2015.

/s/ Deborah Swan

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CERTIFICATE OF COMPLIANCE AND OF SERVICE

I, Deborah Swan, made a good faith efforts to confer with the opposing attorney James
Leuenberger, about witnesses and having limited discovery.

I attached below the emails sent and received between myself and James Leuenberger.
I listed the witnesses I plan on calling and Leuenberger did not oppose when he
responded to my email.
I served James Leuenberger by e file a copy of the AFFIDAVIT AND MOTION FOR
LIMITED DISCOVERY AND COMMISSION TO TAK OUT-OF-STATE
TELEPHONIC DEPOSITIONS.

Dated this 12th day of February, 2015.

/s/ Deborah Swan pro se

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Mr. Leuenberger,
This is my second request for a response. Please let me know your thoughts on a poly graph. I have been
researching into it, and since this is civil, we can use this as evidence. I have been speaking with 2 people
out of Oregon who are experienced with how to work within the rules of procedure and rules of evidence.
Please let me know so I can get an idea where you stand then we can set up a meeting to discuss this.
The following are the topics I want to focus on for my poly graph exam are :
accused of stealing 1900.00 donations I have been accused of stealing
accused of stealing from Charles and dumping him in Texas
accused of stealing donations from Charles Dyer
accused of stealing donations from the Dollars 4 Dyer Money Bomb
accused of keeping donations from supporters who claim they sent me money to me for Charles
accused of telling Ed Snook I used donations for personal use.
accused of working for the FBI as a snitch
accused of being released early from Federal Prison
accused of draining bank accounts of married men
accused of running around the country with a firearm
accused of ranting to Ed Snook about 911 and the OKC Bombing
accused of asking Ed Snook to investigate the US Government
accused of being involved in dangerous anti government militia groups
accused of attacking the supporters around Janet Dyer
accused of calling Janet Dyer and screaming and cussing at her on the phone
accused of harassing the family of Charles Dyer
accused of going to talk to Valerie Dyer
accused of leading Charles Dyer to the FBI to collect grandson money
accused of threats to shoot the Attorney Albert Hock
accused of telling Mrs. Mortenson that she better get out of her house cause I am moving in..
accused of ranting to Ed Snook about OKC Bombings and 911
accused of having 20 phone calls with Ed Snook
accused of being a paranoid shcitzophrentic
accused of refusing to leave Janet Dyer's property
accused of being a dangerous lunatic
accused of calling Ed Snook and cussing and hanging up on him
accused of not leaving Ed snook alone so he could do the investigation
accused of harassing Ed Snook and he could not work on what he needed to work on
accused of interfering with Ed Snook's ability to get to the people he needed to get to out in Oklahoma
accused of having my pacer records sealed
accused of ruining the investigation for Charles Dyer

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accused of attacking the support team around Janet Dyer

accused of calling everyone a Fed
accused of filing false charges against the US Observer

Please share this list with Ed and if I left anything off, fell free to ad to the list.
I have an offer for Ed Snook:
I will make this offer. We both agree to pay our own fee's for the polygraph exam, and who ends up
wining in the end will add the cost of the polygraph to the final award for damages. We both agree to
release the poly graph exam results to the public and give each other permission to use and republish as
many times desired. The poly graph examiner has to be agreed upon first. I will have a attorney step in to
assist with this if you agree. Lets keep the polygraph exam under $2000.00 if possible. For the record I
will not be paying for my exam. I have friends who offered to help pay.
Second request for Discovery . Do you have any issues with requesting limited discovery for this
upcoming hearing? I will be using the Youtube Video that I have published during the hearing, and will be
requesting to call the following witnesses to attend telephonically. Those will be Gary Hunt, Robert
Smith, Nick Parisi, Chris Mortenson, Mrs. Mortenson, Edogz818, Amy Dark, Ron Lee, Lorne Dey, Janet
Dyer, Michele School, and if I am able to work it out, Charles Dyer. I also want to call the 3 people with
whom Ed Snook claims he contacted when Ed was collecting information against myself and Chris for
his article. I think requesting limited discovery is critical for both of our positions.
Please respond,
Thanks,
Deborah

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