FINAL GIUSTO Investigative Report #1 01 16 08 PDF

DPSST Investigation #1 - GIUSTO
Bernard GIUSTO
Investigation #1
Bernard GIUSTO DPSST# 07617

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TABLE OF CONTENTS
A.
CASE IN BRIEF..................................................................................................................... 7
1. KIM complaint.................................................................................................................... 7
2. LEONHARDT complaint ................................................................................................... 7
3. NAITO/PAUGH complaint ................................................................................................ 7
4. Anonymous Lead GIUSTO/BICART.............................................................................. 7
5. Investigative Team identified ............................................................................................. 8
B. OVERVIEW ........................................................................................................................... 8
1. DPSST Jurisdiction and Scope of Investigation ................................................................. 8
2. Oregon Department of Justice investigation versus DPSST investigation......................... 8
3. Background on Sheriff Bernard GIUSTO .......................................................................... 9
4. Findings Categories .......................................................................................................... 10
5. Investigative Team Discussion and Findings ................................................................... 10
C. REGULATORY STATUTES, ADMINISTRATIVE RULES AND LEGAL CRITERIA . 11
1. Standard of Proof .............................................................................................................. 11
2. Criminal Justice Code of Ethics........................................................................................ 11
3. Statutes and Administrative Rules .................................................................................... 11
1) Statutes and Rules establishing minimum standards .................................................... 11
2) Statutory and regulatory authority to revoke for violation of moral fitness standards . 11
3) Definition of Moral Fitness........................................................................................... 11
4) Oregon Revised Statute statute of limitations............................................................ 12
5) Oregon Revised Statute mandatory reporting sexual abuse of child .......................... 12
6) Criminal conduct, as affected by the statute of limitations........................................... 12
7) ORS 206.010 ORS 206.345 General duties of sheriff. ............................................. 13
8) ORS 166.291 The criteria for issuance of a Concealed Handgun License. .................. 13
9) ORS Impact of revocation on currently elected sheriff. ............................................ 13
10)
Brady Issues .............................................................................................................. 13
11)
Legal Definition of Corroboration, Corroborate....................................................... 13
D. MENTIONED PERSONS .................................................................................................... 14
E. EXHIBIT LIST ..................................................................................................................... 23
F. ALLEGATIONS................................................................................................................... 39
1. Summary Table................................................................................................................. 39
2. Allegations Itemized ......................................................................................................... 41
1) Allegation 1: GIUSTO failed to use outside investigators to investigate racial
harassment............................................................................................................................. 41
2) Allegation 2: GIUSTO failed to investigate the conduct of a law enforcement sergeant
involved with the wife of another member. .......................................................................... 44
3) Allegation 3: GIUSTO instigated a misuse of leave complaint against a female
sergeant, which was ultimately overturned........................................................................... 45
4) Allegation 4: GIUSTO had knowledge of GOLDSCHMIDTs crime against a child
and did not report it............................................................................................................... 46
5) Allegation 5: GIUSTOs statements to the public, in 2004 and later, about his
knowledge, or the extent of his knowledge, of the Goldschmidt crime are in conflict with

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statements obtained during the course of the investigation. ................................................. 48
6) Allegation 6: GIUSTO had improper contact with Margie GOLDSCHMIDT. .......... 59
7) Allegation 7: GIUSTO had an inappropriate relationship with a female Gresham City
Councilwoman while he was the Chief of Gresham Police Department.............................. 60
8) Allegation 8: GIUSTO had inappropriate communications with a female subordinate
which resulted in threats to her. ............................................................................................ 62
9) Allegation 9: GIUSTO had an inappropriate relationship with a female volunteer
Chaplain, which affected the current male chaplains employment contract and resulted in a
loss of pay. ............................................................................................................................ 64
10)
Allegation 10: GIUSTO pursued a female PPB employee at a retirement dinner.
65
11)
Allegation 11: GIUSTO inappropriately approved JEDDELOHs concealed
handgun license..................................................................................................................... 66
12)
Allegation 12: GIUSTOs statements to the public, in 2005 and 2007, and regarding
his knowledge of JEDDELOHs DUII diversion and domestic violence incident are in
conflict with statements made to DOJ investigators and physical evidence obtained during
the course of the investigation. ............................................................................................. 67
13)
Allegation 13 GIUSTO altered, or had altered, JEDDELOHs concealed handgun
license application and file.................................................................................................... 75
14)
Allegation 14: GIUSTO misused the protective order that Lee (JEDDELOH) DOSS
obtained by threatening Jim JEDDELOH............................................................................. 76
15)
Allegation 15: GIUSTO engaged in a personal relationship with Lee (JEDDELOH)
DOSS arising from GIUSTOs efforts to conceal his previous bad act, i.e., the issuance of a
Concealed Handgun License................................................................................................. 77
16)
Allegation 16: GIUSTO violated agency policy by sending numerous emails to Lee
DOSS from his work computer............................................................................................. 78
17)
Allegation 17: GIUISTOs statements to the public in 2005, and in a 2006
deposition regarding a trip to Seattle with Lee DOSS while her husband was in
rehabilitation, are in conflict with statements he made to DPSST. ...................................... 79
18)
Allegation 18: GIUSTO has lost public confidence as the result of the prior
allegations, and that the Board of Multnomah County Commissioners made an inquiry
whether criminal conduct was involved but failed to determine if moral fitness issues would
disqualify GIUSTO............................................................................................................... 85
19)
Allegation 19: KIM asserted the Oregon Department of Justice investigation against
GIUSTO was tainted in the publics eye as a result of political connections between
GIUSTO and KULONGOSKI. ............................................................................................. 86
20)
Allegation 20: GIUSTO improperly appeared in uniform to campaign for
KULONGOSKI. ................................................................................................................... 87
21)
Allegation 21: GIUSTO has demonstrated poor management as shown by the
Investigative Report conducted by the Multnomah County District Attorneys Office. ...... 88
22)
Allegation 22: GIUSTO has failed to maintain a high ethical standard, and therefore
his subordinates have engaged in similar conduct that has led to some subordinate officers
arrests. 89
23)
Allegation 23: GIUSTO has been publicly humiliated through the media. ............. 90
24)
Allegation 24: GIUSTO improperly directed his staff to check Complainant Robert
KIM in LEDS........................................................................................................................ 91

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G.
H.
INVESTIGATIVE ACTIONS TAKEN ............................................................................... 92

Interview Sequence, Questions, Summaries and Validation .............................................. 111
1. Interview Sequence......................................................................................................... 111
2. Helen (Foster) BICART Questions................................................................................. 113
3. Helen (Foster) BICART Interview Summary................................................................. 113
4. Therese BOTTOMLY, Oregonian.................................................................................. 114
5. Therese BOTTOMLY, Oregonian Message Summary .................................................. 114
6. John BRANDT (freelance writer)................................................................................... 115
7. Nick BUDNICK, Portland Tribune ................................................................................ 116
8. State Senator Ginny BURDICK Interview Questions .................................................... 117
9. State Senator Ginny BURDICK Interview Summary .................................................... 118
10. Robert BURTSCHAELL Interview Questions............................................................... 121
11. Robert BURTSCHAELL Interview Summary ............................................................... 122
12. Kathy BUTTS Interview Questions................................................................................ 124
13. Kathy BUTTS Interview Summary ................................................................................ 124
14. MCSO Deputy Sean CHRISTIAN Interview Questions ................................................ 125
15. MCSO Deputy Sean CHRISTIAN Interview Summary ................................................ 126
16. MCSO Deputy Rafael CORTADA Interview Questions ............................................... 130
17. MCSO Deputy Rafael CORTADA Interview Summary............................................. 131
18. Ruth Ann DODSON Interview Questions...................................................................... 133
19. Lee (Jeddeloh) DOSS Interview Questions .................................................................... 134
20. Lee (Jeddeloh) DOSS Interview Summary..................................................................... 134
21. MCSO Capt. Brett ELLIOTT Interview Questions........................................................ 135
22. MCSO Captain Brett ELLIOTT Interview Summary .................................................... 137
23. Harry ESTEVE, Oregonian ............................................................................................ 139
24. MCSO Lt. Jason GATES Interview Questions............................................................... 140
25. MCSO Lt. Jason GATES Interview Summary ............................................................... 141
26. Ryan GEDDES, Portland Tribune .................................................................................. 142
27. MCSO Sheriff Bernard GIUSTO Interview Questions .................................................. 143
28. MCSO Sheriff Bernard GIUSTO Interview Summary................................................... 148
29. KIM GIUSTO Interview Questions................................................................................ 159
30. KIM GIUSTO Interview Summary ................................................................................ 159
31. Tom GIUSTO Interview Questions ................................................................................ 160
32. Tom GIUSTO Interview Summary #1 ........................................................................... 161
33. Tom GIUSTO Interview Summary #2 ........................................................................... 161
34. Margie GOLDSCHMIDT Interview Questions.............................................................. 163
35. Margie GOLDSCHMIDT Interview Summary .............................................................. 165
36. Neil GOLDSCHMIDT Interview Questions .................................................................. 169
37. Neil GOLDSCHMIDT Interview Summary................................................................... 170
38. Lee GRAHAM Interview #1 Questions ......................................................................... 171
39. Lee GRAHAM Interview #1 Summary.......................................................................... 172
40. Lee GRAHAM Interview #2 Questions ......................................................................... 175
41. Lee GRAHAM Interview #2 Summary.......................................................................... 175
42. Aimee GREEN, Oregonian............................................................................................. 176
43. MCSO Deputy Mark HERRON Interview Questions .................................................... 177
44. MCSO Deputy Mark HERRON Interview Summary .................................................... 177

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OSP (ret.) James HINKLEY Questions.......................................................................... 179

OSP (ret.) James HINKLEY Interview Summary.......................................................... 179
Tom IMESON Interview Questions ............................................................................... 182
Tom IMESON Interview Summary................................................................................ 183
James JEDDELOH Interview Questions ........................................................................ 185
James JEDDELOH Interview Summary ........................................................................ 186
Gregg KANTOR Interview Questions............................................................................ 187
Gregg KANTOR Interview Summary ............................................................................ 188
Debby (Stone) KENNEDY Interview Questions ........................................................... 192
Debby (Stone) KENNEDY Interview #1 Summary....................................................... 193
Debby (Stone) KENNEDY Interview #2 Summary....................................................... 195
Robert KIM Interview #1 Questions............................................................................ 196
Robert KIM Interview #1 Summary ............................................................................... 200
Robert KIM - Interview #2 Questions ............................................................................ 205
Robert KIM #2 Interview Summary ............................................................................... 205
Robert KIM - Interview #3 Questions ............................................................................ 205
Robert KIM #3 Interview Summary ............................................................................... 205
MCSO Chief of Staff Christine KIRK Interview Questions .......................................... 206
MCSO Chief of Staff Christine KIRK Interview Summary........................................... 207
Governor Ted KULONGOSKI Interview Questions ..................................................... 208
Governor Ted KULONGOSKI Interview Summary...................................................... 209
Christy LEONHARDT Interview Questions .................................................................. 210
Christy LEONHARDT Interview Summary .................................................................. 211
Fred LEONHARDT Interview Questions ...................................................................... 214
Fred LEONHARDT Interview Summary....................................................................... 215
Jeff MAPES, Oregonian ................................................................................................. 217
MCSO Lt. Bruce MCCAIN Conversation Summary .................................................. 217
MCSO Civilian Deirdre McGILL Interview Questions ................................................. 217
MCSO Civilian Deirdre McGILL Interview Summary.................................................. 217
Jacquenette McINTIRE Interview Questions ................................................................. 217
Jacquenette McINTIRE Interview Summary.................................................................. 217
MCSO Tim MOORE ...................................................................................................... 217
Multnomah County Commissioner Lisa NAITO Interview Questions .......................... 217
Multnomah County Commissioner Lisa NAITO Interview Summary........................... 217
Chief Garr NIELSEN, Interview Questions ................................................................... 217
Chief Garr NIELSEN Interview Summary..................................................................... 217
Debby NOAH Interview Questions ................................................................................ 217
Debby NOAH Interview Summary ................................................................................ 217
MCSO Deputy Bobby ODONNELL Interview Questions ........................................... 217
MCSO Deputy Bobby ODONNELL Interview Summary............................................ 217
MCSO Sergeant Diana OLSEN Interview Questions .................................................... 217
MCSO Sergeant Diana OLSEN Interview Summary..................................................... 217
MCSO HR Director Jennifer OTT Interview Questions ................................................ 217
MCSO HR Director Jennifer OTT Interview Summary................................................. 217
MCSO Detective Jay PENTHENY Interview Questions ............................................... 217
MCSO Detective Jay PENTHENY Interview Summary................................................ 217

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91. MCSO Lt. Dave RADER Interview Questions .............................................................. 217
92. MCSO Lt. Dave RADER Interview Summary............................................................... 217
93. Jim REDDEN Portland Tribune ..................................................................................... 217
94. MCSO Sgt. Brent RITCHIE Interview Questions.......................................................... 217
95. MCSO Sgt. Brent RITCHIE Interview Summary .......................................................... 217
96. MCSO Deputy Marshall ROSS Interview Questions..................................................... 217
97. MCSO Deputy Marshall ROSS Interview Summary ..................................................... 217
98. Jacob SANDERS, Portland Tribune ............................................................................... 217
99. Senate Rules Testimony.................................................................................................. 217
100. MCSO Deputy Todd SHANKS, Interview Questions.................................................... 217
101. MCSO Deputy Todd SHANKS, Interview Summary .................................................... 217
102. Phil STANFORD, Portland Tribune............................................................................... 217
103. Follow up questions related to news article quotes: ....................................................... 217
104. Chaplain Ed STELLE Interview Questions.................................................................... 217
105. Chaplain Ed STELLE Interview Summary .................................................................... 217
106. Arthur SULZBERER, Oregonian ................................................................................... 217
107. Victoria TAFT, News Talk 860 Summary ..................................................................... 217
108. Chaplain Alice TATE Interview Questions.................................................................... 217
109. Chaplain Alice TATE Interview Summary .................................................................... 217
110. Vicky THOMPSON Interview Questions ...................................................................... 217
111. Vicky THOMPSON Interview Summary....................................................................... 217
112. MCSO Deputy Jose TORRES Interview Questions....................................................... 217
113. MCSO Deputy Jose TORRES Interview Summary ....................................................... 217
114. Angela VALDEZ, Willamette Week.............................................................................. 217
115. Senator Vicki WALKER Interview Summary ............................................................... 217
116. MCSO Kathy WALLIKER Interview Summary............................................................ 217
117. MCSO Sgt. Ned WALLS Interview Summary............................................................... 217
118. Brent WALTH, Oregonian ............................................................................................. 217
119. MCSO Deputy Tim WONACOTT Interview Questions................................................ 217
120. MCSO Deputy Tim WONACOTT Interview Summary ................................................ 217
121. Roger WOOD Interview Questions ................................................................................ 217
122. Roger WOOD Interview Summary ................................................................................ 217
123. David YADEN Interview Questions .............................................................................. 217
124. David YADEN Interview Summary............................................................................... 217
125. Debbie YOUMANS Interview Questions ...................................................................... 217
126. Debby YOUMANS Interview Summary........................................................................ 217
127. Les ZAITZ, Oregonian ................................................................................................... 217
I. INDEX ................................................................................................................................ 217

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A. CASE IN BRIEF
1. KIM complaint
In April 2007, the Department of Public Safety Standards and Training (DPSST) received
allegations from Robert KIM of numerous acts of misconduct by Sheriff Bernard
GIUSTO. During the course of the investigation, KIM asserted that he had received his
information second and third hand from MCSO sources which he could not or would not
identify. Investigators found most of KIMs allegations inaccurate, not within DPSSTs
jurisdiction or reporting conduct which did not constitute misconduct within DPSSTs
jurisdiction. Of the twenty-three (23) allegations, twenty-one of the allegations were
administratively closed. One of KIMs allegations, that GIUSTO misrepresented to the
public his knowledge of James JEDDELOHs prior criminal history when he initially
approved the concealed handgun license, was referred to the Police Policy Committee for
review. A second allegation relating to Lee DOSS, was narrowed to focus on whether
GIUSTO traveled to Seattle with DOSS after the intervention with JEDDELOH. This
allegation was referred to the Police Policy Committee for review. 1
2. LEONHARDT complaint
In June 2007, DPSST received specific allegations from Fred LEONHARDT, which
included his first-hand recollections. LEONHARDT asserted that while Bernard GIUSTO
was a certified police officer working a security detail for Governor Neil
GOLDSCHMIDT, GIUSTO gained knowledge that GOLDSCHMIDT had engaged in the
crime of sexual abuse of a minor child while GOLDSCHMIDT was the Mayor of Portland.
LEONHARDT asserted that GIUSTO told LEONHARDT of the crime. LEONHARDT
alleged that GIUSTO misrepresented to the public his knowledge, or the extent of his
knowledge about the GOLDSCHMIDT crime. This allegation was referred to the Police
Policy Committee. 2
3. NAITO/PAUGH complaint
In June 2007, DPSST received a complaint from Mr. PAUGH through Commissioner Lisa
NAITOs office, alleging that GIUSTO improperly used the Law Enforcement Data
System (LEDS) to conduct a background check on KIM. This allegation was
administratively closed; GIUSTOs actions did not constitute misconduct.3
4. Anonymous Lead GIUSTO/BICART
In June 2007, DPSST received an email asserting that BICART could have information
relating to GIUSTOs knowledge of the GOLDSCHMIDT crime. BICART was
1
Ex A1a
Ex A15a
3
Ex A16a
2

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interviewed and asserted that GIUSTO had never shared with her any knowledge he may
have had4. BICARTs close associate, Debbie YOUMANS was also contacted and
asserted that BICART had not shared with her any information obtained from GIUSTO.5
This allegation was administratively closed.
5. Investigative Team identified
At the direction of Director MINNIS, an investigative team was identified and met to
discuss the investigative plan and investigative logistics. The investigative team was
comprised of the following: DPSST Investigators Theresa KING and Shirley PARSONS,
DPSST Legal Services Coordinator Lorraine ANGLEMIER, Esq., AAG Darin TWEEDT,
Oregon Department of Justice, whose role was to provide the team with legal advice.6
The investigative team addressed each allegation to determine whether it was within
DPSSTs jurisdiction; if so, if there was evidence to substantiate it; and if substantiated,
what the appropriate course of action should be.
B. OVERVIEW
The following information will provide an overview of the scope of the investigation and the
related statutes and rules.
1. DPSST Jurisdiction and Scope of Investigation
During this investigation, DPSST was provided information covering a wide variety of
subject areas. This investigation remained solely focused on the issues over which
DPSST has jurisdiction; i.e., whether any actions by GIUSTO violated the established
standards for Oregon public safety officers. Issues relating to leadership styles,
personnel, employment practices, and agency operations, are not under DPSST
jurisdiction. These issues, and allegations regarding violation of agency policy, were
addressed to the extent that a determination could be made regarding whether they
impacted minimum standards for Oregon public safety officers.
2. Oregon Department of Justice investigation versus DPSST investigation.
The Oregon Department of Justice (DOJ) conducted a 2005-2006 investigation
surrounding two specific events; GIUSTOs involvement in JEDDELOHs concealed
handgun license (CHL) application, and the intervention involving Jim JEDDELOH
that resulted in his entering an alcohol rehabilitation center. DOJs focus was strictly to
determine violation of any criminal laws.
Regarding the concealed handgun license application, DOJ found, in part, Giustos
involvement in Jim Jeddelohs license application was an exercise of his official duties as
4
Ex A18b
Ex A19e
6
Ex A2a, A2b
5

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sheriff. (ref ORS 162.415) The authority of a county sheriff to approve and issue
concealed handgun licenses is prescribed by statute. (Ref ORS 166.291) As an elected
official responsible for administering his own agency, Giusto has the authority to set and
modify policy, and has broad discretion in defining and exercising his duties, (Ref ORS
206.010 206.345) (emphasis added) . . .Although Giusto initially approved Jeddelohs
concealed handgun license application, he revoked his initial approval before it took
effect. No license ever issued. In sum, Giusto never exercised his power in an
unauthorized manner.
Regarding the intervention, DOJ found in part, The legal issue is whether Giustos
participation in the intervention constitutes the criminal offense of official misconduct. . .
it does not appear that Giustos involvement in the intervention was an unauthorized
exercise of official duties . . . Giusto helped facilitate the intervention. There is no
express statutory or policy prohibition against a sheriff doing so. He directed that
members of his staff be available to assist in the process. Such an allocation of resources
is consistent with a sheriffs authority to execute process, and preserve peace. . . . there is
some evidence that Giusto used the threat of service of a restraining order as a tool to
force Jim Jeddeloh to attend the Betty Ford Clinic. The restraining order had been
lawfully issued by a court. Giusto was authorized by law to cause its service. Under the
circumstances, Giustos threat to do something he had a legal right to do cannot be said to
constitute an unauthorized exercise of official duties.
The Oregon Department of Justice concluded, Because there is insufficient evidence to
conclude that Giusto participated in the intervention in order to facilitate a relationship
with Lee Jeddeloh or obtain any other personal benefit and because there is insufficient
evidence that Giusto engaged in an unauthorized exercise of official duties, we decline to
pursue criminal charges in this matter. 7
In contrast, the focus and scope of DPSSTs review is on the minimum standards for
Oregon public safety officers, as detailed in ORS 181.640 - ORS 181.662 and OAR 259008-0010 OAR 259-008-0070.
3. Background on Sheriff Bernard GIUSTO
GIUSTO began his public safety career on October 1, 1974, as a police officer with the
Oregon State Police. On January 1, 1985, GIUSTO was promoted to Sergeant and on
March 1, 1988, was reclassified to Lieutenant. On July 31, 1996, GIUSTO resigned from
the Oregon State Police (OSP).
On August 1, 1996, GIUSTO was hired as the Chief of Police for the Gresham Police
Department and served in this position until December 2, 2002.
In 2002 GIUSTO was first elected as the Sheriff of Multnomah County. On January 1,
2003, he began serving in this position. In May of 2006, GIUSTO was re-elected to the
office of Sheriff.
7
Ex A9a

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During GIUSTOs public safety career he has attained Basic, Intermediate, Advanced,
Supervisory, Management and Executive Police certificates. GIUSTO has approximately
1,900 hours of state-reported public safety training. 8
4. Findings Categories
For the purposes of this investigation, the following categories will be used for each
allegation:
Administrative Closure:
The allegation(s) is false; or
The conduct does not constitute misconduct for purposes of DPSST
jurisdiction; or
The conduct is not within DPSSTs jurisdiction; or
There is no way to prove or disprove the allegation; or
The allegation is of a minor nature that would not result in revocation, even if
proven true.
Referred:
The conduct is within DPSSTs jurisdiction, and
The conduct may have violated the established standards for Oregon public
safety officers, thereby requiring the matter to be forwarded to the Police
Policy Committee for review.
Referred To Another Agency:
The conduct is not within DPSST jurisdiction, or
The conduct may be within DPSSTs jurisdiction but may be criminal;
therefore DPSST defers case to appropriate jurisdiction for review.
The conduct may be within DPSSTs jurisdiction but may also be within
another agencys jurisdiction; therefore DPSST defers the case to the appropriate
jurisdiction for review.
5. Investigative Team Discussion and Findings

The Investigative Team concludes there is sufficient cause to refer Allegations 5, 12 and
17, Part A, to the Police Policy Committee for review to determine if Bernard GIUSTO
has fallen below the established standards for Oregon public safety officers.
Ex A7

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C. REGULATORY STATUTES, ADMINISTRATIVE RULES AND LEGAL CRITERIA
1. Standard of Proof
The standard of proof on this matter is a preponderance of evidence; evidence that is of
greater weight and more convincing than the evidence offered in opposition to it; more
probable than not.9
2. Criminal Justice Code of Ethics
Regarding the Criminal Justice Code of Ethics, to be eligible for certification OAR 259008-0060, a police officer must subscribe to and swear or affirm to abide by the Code of
Ethics (Form F-11). This Code states in part, Honest in thought and deed in both my
personal and official life, I will be exemplary in obeying the laws of the land and the
regulations of my department.
3. Statutes and Administrative Rules
1)
Statutes and Rules establishing minimum standards
ORS 181.640(1)(a) states that the Department and the Board shall establish minimum
standards for moral fitness for public safety personnel. OAR 259-008-0010(6) establishes
the minimum standards for moral fitness.
2)
Statutory and regulatory authority to revoke for violation of moral fitness standards
Pursuant to ORS 181.640, ORS 181.661, ORS 181.662(1)(c) and OAR 259-008-0070(1)
and (3(C) the Department may revoke the certifications of a public safety officer who
does not meet the minimum standards for moral fitness established pursuant to ORS
181.630, ORS 181.640(1)(a).10
3)
Definition of Moral Fitness
According to OAR 259-008-0010(6)(a), the phrase lack of good moral fitness means
conduct not restricted to those acts that reflect moral turpitude but rather extending to
acts and conduct which would cause a reasonable person to have substantial doubts about
the individuals honesty, fairness, respect for rights of others, or for the laws of the state
and/or nation.11
Indicators of lack of moral fitness:
Under OAR 259-008-0010(6)(b), the following are indicators of lack of good
moral fitness:
Illegal conduct involving moral turpitude;
Conduct involving dishonesty, fraud, deceit, or misrepresentation;
Intentional deception or fraud or attempted deception or fraud in any
application, examination, or other document for securing certification or
eligibility for certification;
9
Oregon Attorney Generals Administrative Law Manual and Uniform Model Rules of Procedure under the
Administrative Procedures Act, Standard of Proof, p. 142 (2006)
10
Ex A11
11
Ex A10
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4)
Conduct that is prejudicial to the administration of justice;

Conduct that adversely reflects on his or her fitness to perform as a law
enforcement officer. Examples include but are not limited to: Intoxication
while on duty, untruthfulness, unauthorized absences from duty not involving
extenuating circumstances, or a history of personal habits off the job which
would affect the officers performance on the job which makes the officer
both inefficient and otherwise unfit to render effective service because of the
agencys and/or publics loss of confidence in the officers ability to perform
competently.
Oregon Revised Statute statute of limitations

ORS 131.125 identifies the time limitations often referred to as the statute of
limitations. Prior to 1989, the statute of limitations for all felonies was three years.
Amendments occurred in 1989 and 1991 that considerably extended the time
period for all sex crime felonies, and particularly for crimes against children,
including the statutory rape crimes. 12
5)
Oregon Revised Statute mandatory reporting sexual abuse of child

ORS 419B.010. The Oregon Legislature did not pass Oregons mandatory
reporting law until 1993. 13
6)
Criminal conduct, as affected by the statute of limitations

ORS 131.005 defines criminal action. ORS 161.515 defines the term crime.
ORS 131.105 through ORS 131.155 is the statutory scheme covering time
limitations.
At the request of KING, ANGLEMIER prepared a memorandum clarifying how, if
at all, the statute of limitations for a crime affected the criminality of the
underlying conduct. ANGLEMIER concluded, While a time limitation may bar a
criminal action from being commenced, there is nothing, by operation of statute,
which suggests there is no crime and/or no victim.14
(cross reference page 148, GIUSTOs Interview Summary)
It is on the basis of ANGLEMIERs research that the term Goldschmidts crime
is used.
12
Ex A6b, A6c
Ex A6b
14
Ex A6k
13

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7)
ORS 206.010 ORS 206.345 General duties of sheriff. 15

This statute provides an overview of the qualification and general duties of a
Sheriff, as well as a Sheriffs authority.
8)
ORS 166.291 The criteria for issuance of a Concealed Handgun License.

At the request of KING, ANGLEMIER prepared a memorandum providing an
overview of the authority of a Sheriff to issue a CHL and restrictions that would
prohibit a Sheriff from issuing a CHL.16 (cross-reference page 148, GIUSTOs
interview summary)
9)
ORS Impact of revocation on currently elected sheriff.17

The issue of whether GIUSTO may still hold office if his police certifications are
revoked has not been addressed by this investigative team.
10)
Brady Issues
At the request of KING, ANGLEMIER and LORANCE provided the document,
Truthfulness and Public Safety Professionals Court Decisions.18
11)
Legal Definition of Corroboration, Corroborate

At the request of KING, ANGLEMIER prepared a memorandum clarifying the
legal definition of corroboration and corroborate. This was in response to
MCCAINs suggestion, in the GIUSTO response, that a different definition be
applied.
Corroboration:
The term corroborate or corroboration appears frequently in this Investigative
Report. In the interest of clarity, the Investigative Team relied on the following
definition provided in the Blacks Law Dictionary, Eighth Edition (2004) .
Corroboration: To strengthen or confirm; to make more certain.
15
Ex A13
Ex A6l
17
Ex A4a
18
Ex A6h
16

Investigation #2
Page 13 of 302
1/16/2008

D. MENTIONED PERSONS
Name
Phone
Address
ANGLEMIER, Lorraine
503 378 2214
DPSST
Legal Services Coordinator
lorraine.anglemier@state.or.us
4190 Aumsville Hwy SE

Salem, Oregon 97317
ANDERCHUCKI, Phil
503 310 1631 Cell
MCSO Corrections Union

President
BICART, Helen (Foster)
503 969 5714
Former chief of Lake

Oswego
5205 NE Barnes Road

Madras, Oregon 97741
BRANT, John
NV
2940 NE Klickitat Street
Reporter
503 288 3146
Portland, Oregon 97212
BUDNICK, Nick
503-546-5145
nickbudnick@portlandtribune.co
m
Portland Tribune
Reporter
BURDICK, Ginny
503 244 1444 Office
State Senator
BURTSCHAELL, Robert
503 284 8976
4150 NE Beaumont St
Bobcat97080@yahoo.com
Former Gresham City

Councilwoman
CHRISTIAN, Sean
4641 SW Dosch Road

GOLDSCHMIDTs friend
BUTTS, Kathy
6605 S.E. Lake Road

Portland, OR 97222
1548 SE 11th Street

Gresham, Oregon 97080
503 251 2451
MCSO Deputy
MCSO
12240 NE Glisan St
CORTADA, Rafael
503 251 2451 Office
MCSO Deputy
MCSO
12240 NE Glisan St
DODSON, Ruth Ann
NV
5232 SW Bancroft St
GOLDSCHMIDT
administration
503 297 4856

Investigation #2
Page 14 of 302
1/16/2008

DUNCAN, Scott
503 988 6161
MCSO Chaplain
DOSS, Lee (Jeddeloh)
503 221 1116 Residence
1210 SW Myrtle Drive
971 221 7593 Cell
ESTEVE, Harry
503-221-8226
Oregonian
Reporter
harryesteve@news.oregonian.co
m
1320 SW Broadway
Portland, OR 97201
FRANCESCONI, Jim
NA
GATES, Jason
503 251 2451 Office
MCSO
Sergeant (promoted to Lt)
503 793 6553 Cell
12240 NE Glisan St
GEDDES, Ryan
Portland Tribune
Reporter
Ryan
ryangeddes@portlandtribune.co
m
GIUSTO, Bernard
(503) 988 - 4300
MCSO
6605 S.E. Lake Road

Portland, OR 97222
MCSO Sheriff
501 SE Hawthorne Blvd,

Suite 350
GIUSTO, KIM
503 665 5928
Bernard GIUSTOs exwife

GIUSTO, Tom
503 666 4525
Bernard GIUSTOs brother
503 348 0158

503 313 2411
123 E. Powell Blvd, Suite

101
503 489 1723

GLYNN, Mary Ellen
503 378 4582
160 State Capitol

900 Court Street
Salem, Oregon 973014047
503 793 2388 Nextel
Gresham Police
Department
KULONGOSKIs
administration
GRAHAM, Lee
Frmr Chief Deputy, MCSO 503 618 2318

Current Officer Gresham
PD
lee.graham@ci.gresham.or.us
1333 NW Eastman
Parkway

Investigation #2
Page 15 of 302
1/16/2008

GOLDSCHMIDT, Margie
503 281 3096
Former wife of Neil

GOLDSCHMIDT
3233 NE 32nd Pl
Prior relationship with

Bernard GIUSTO
GOLDSCHMIDT, Neil
503 206 6199
Former Oregon Governor
1150 King SW Avenue

GREEN, Aimee
503 294 5119
Oregonian
Reporter
aimeegreen@news.oregonian.co
m
1320 SW Broadway
HASLER, Carol
503 988 4407
MCSO
MCSO Inspector
carol.hasler@mcso.us
Portland, OR 97201
Suite 350
IMESON, Thomas
503 282 3668
GOLDSCHMIDT Chief of
Staff
1809 NE Klickitat Street

JAQUISS, Nigel
Reporter
503 243-2122
njaquiss@wweek.com
Willamette Week
2220 NW Quimby
Portland, OR 97210
JEDDELOH, Jim
503 781 1272
6150 SW Arrowwood
Lane
Former husband of Lee

(JEDDELOH) DOSS
Subject of intervention
KANTOR, Gregg S
503 244 3472
Communications
Supervisor
1709 SW Westwood
Court
GOLDSCHMIDT
Administration
KATZ, Vera
1511 SW Park Ave #901
Former Mayor, City of

Portland

Investigation #2
Page 16 of 302
1/16/2008
KENNEDY, Debbie
(Stone)
503 203 2559
8927 NW Rockwell Lane

KIM, Robert
503 524 1051
14040 SW 131st Terrace
Complainant #1
503 780 0232
Tigard, Oregon 97224
KING, Theresa
503 378 2305
DPSST
DPSST Investigator

Salem, Oregon 97317
KIRK, Christine
503 988 4301 Office
MCSO
MCSO Chief of Staff
503 209 6200 Cell

Suite 350
KULONGOSKI, Ted and

wife Mary Oberst
503 378 4582
160 State Capitol

900 Court Street
Salem, Oregon 973014047
Governor and First Lady

KYLE, Louis
503 988 3757
MCSO Chaplain
LEONHARDT, Fred
503 624 2071 Res
Complainant #2
16175 SW Copper Creek

Drive
Former GOLDSCHMIDT
speechwriter
LEONHARDT, Christy
503 624 2071 Res
16175 SW Copper Creek

Drive
Wife of Fred
LEONHARDT
503 712 8126 Wk
LIM, John
NV
740 SE 25th
State Representative
503 667 3647
503 378 2427
DPSST
Uncle to Complainant #1
KIM
LORANCE, Marilyn
DPSST Supervisor of
Standards and Certification

Investigation #2
Page 17 of 302

Salem, Oregon 97317
1/16/2008

MALIN, Dan
503 378 3055, ext 55007
LEDS Auditor
LEDS
P. O. Box 14360
Salem, Oregon 97309
MAPES, Jeff
503-221-8209
Oregonian
Reporter
jeffmapes@news.oregonian.com
1320 SW Broadway
Portland, OR 97201
McBETH, Page
503 378 6347
DOJ Investigator
DOJ
610 Hawthorne Avenue
SE
Salem, Oregon 97301
MCCAIN, Bruce
503 572 7768 Nextel
MCSO Lieutenant,
Executive Staff
503 988 4325
McDADE, Karl
NA
McGILL, Deirdre
503 255 3600, ext 459
MCSO Civilian Staff
MCSO
12240 NE Glisan St
McINTIRE, Jacquenette
503 706 3453
Former Gresham City

Councilwoman
MINNIS, John
503 378 2042
DPSST Director
DPSST
Salem, Oregon 97317
MOYER, Catherine
503 988 4404
MCSO Exec Assistant
MCSO
12240 NE Glisan St
MULLMANN, Chris
503 620 0222
Assistant General Counsel
Oregon State Bar

5200 SW Meadows Road
P. O. Box 1689
Lake Oswego, Oregon
97035

Investigation #2
Page 18 of 302
1/16/2008
NAITO, Lisa
503 988 5217
Multnomah County
Commissioner
NOAH, Debby
503 275 1151
732 SW Sleret Avenue

OCONNELL, Terry
503 378 3055
LEDS Director
LEDS
P. O. Box 14360
Salem, Oregon 97309
ODONNELL, Bobby
MCSO
MCSO Deputy
Hansen Building
12240 NE Glisan
ODONNELL, Laura
MCSO
Hansen Building
12240 NE Glisan
OLSEN, Diana
Nextel 503 793 0004
MCSO Sergeant
MCSO
Hansen Building
12240 NE Glisan
OSWALT, Angela
NA
OTT, Jennifer
503 988 4090
Multnomah County
Sheriffs Office
PARSONS, Shirley
503 378 2305
DPSST
DPSST Investigator
Shirley.parsons@state.or.us
MCSO Human Resources

Director
Salem, Oregon 97317

1312 SW 10th Avenue,
Apt 504
PAUGH, Charles
Complainant

RADER, David

Investigation #2
Page 19 of 302
503 251 2451 Office
1/16/2008
MCSO

MCSO Lieutenant
12240 NE Glisan St
Portland Tribune
Reporter
Lead Reporter
503-546-5131
jimredden@portlandtribune.com
REESE, David
503 378 6246
Office of the Governor
General Counsel for

Governor Kulongoski
David..Reese@das.state.or.us
160 State Capitol
REDDEN, Jim
6605 S.E. Lake Road

Portland, OR 97222
900 Court ST NE
Salem, Oregon 97301
RITCHIE, Brent
Multnomah County
Sheriffs Office
MCSO Sergeant
Hansen Building
12240 NE Glisan
ROSS, Marshall
503 255 3600 ext 516 Offic
MCSO
Civil Deputy
503 793 3957
12240 NE Glisan St
SANDERS, Jacob Quinn
jacobsanders@portlandtribune.co
m
Portland Tribune
SHANKS, Todd
503 255 3600 ext 542 Office
MCSO
MCSO Detective
503 793 3949 Cell
12240 NE Glisan St
Reporter
MCDSA Pres
6605 S.E. Lake Road

Portland, OR 97222
SHRUNK, Michael
503-988-3162
Multnomah County
District Attorney
Michael.d.schrunk@mcda.us
Multnomah County
District Attorney
Multnomah County
Courthouse
1021 S.W. Fourth
Avenue, Room 600
Portland, OR 97204
SIMMONS, Ken
Polygraph Licensing
Advisory Committee Chair
STANFORD, Phil
Columnist
Investigation #2
Page 20 of 302
503 654 7327
8305 SE Monterey #220

Portland, OR 97266
503 546 5166
Portland Tribune
6605 S.E. Lake Road
1/16/2008

philstanford@portlandtribune.co
m
Portland, OR 97222
STELLE, Ed
Chaplain
503 255 3600 ext 406 Office

503 793 4196 Cell
SULZBERGER, Arthur
Gregg
Reporter
SKYE, Kelly
503-221-8330
arthursulzberger@news.oregonia
n.com
503 378 6246
MCSO
12240 NE Glisan St
Oregonian
1320 SW Broadway
Portland, OR 97201
Office of the Governor
Deputy General Counsel

for Governor Kulongoski
Kelly.Skye@sate.or.us
160 State Capitol

900 Court ST NE
Salem, Oregon 97301
TATE, Alice
503 665 6212
MCSO Volunteer Chaplain
1275 NE Country Club

Lane
THOMPSON, Vicky
503 661 2552
647 SW Birdsdale Drive
503 725 3759 Wk
TORRES, Jose
MCSO
MCSO Deputy
12240 NE Glisan St
TWEEDT, Darin
503 378 6347
Assistant Attorney General
Darin.tweedt@state.or.us
Oregon Department of
Justice
610 Hawthorne Avenue
SE
Salem, Oregon 97310
VALDEZ, Angela
503 243 2122
Willamette Week
2220 NW Quimby
Portland, OR 97210
WALTH, Brent
503-294-5072
Oregonian
Investigative Reporter
brentwalth@aol.com
1320 SW Broadway
Reporter
Portland, OR 97201
WILSON, Kimberly
503 412 7017
Oregonian
Reporter
KIMberlywilson@news.oregonia
n.com
1320 SW Broadway

Investigation #2
Page 21 of 302
1/16/2008
Portland, OR 97201
YADEN, David
53 636 5088
GOLDSCHMIDT Advisor
Lake Oswego, Oregon

97034
YORK, Derry
503 241 8168 W
Polygraph Examiner
503 422 5699 C
YOUMANS, Debbie H.
275 Northshore Road
1130 SW Morrison St,

Suite 430
503 241 3602 Fax
Portland Oregon 97205
541 475 4242
5205 NE Barnes Road
Named with Bicart in

anonymous complaint
Madras, Oregon 97741
WALTH, Brent
503-294-5072
Oregonian
Reporter
brentwalth@aol.com
1320 SW Broadway
WALKER, Vicki
503 986 1707
900 Court Street NE
541 302 9533
Salem, Oregon 97301
WALLIKER, Kathy
MCSO
12240 NE Glisan St
WALLS, Ned
MCSO
MCSO Sergeant
12240 NE Glisan St
WONACOTT, Tim
MCSO
MCSO Deputy
12240 NE Glisan St
ZAITZ, Les
1-503-585-0985
Oregonian
Reporter
(PDX) 503-221-8181
1320 SW Broadway
503 329 0637
Portland, OR 97201
541 421 3031

leszaitz@news.oregonian.com

Investigation #2
Page 22 of 302
1/16/2008
E. EXHIBIT LIST
Exhibit Date
Description
A1a
04 24 07
4-pg Letter from KIM to MINNIS with 10-pg news clippings
A1b
04 30 07
DMV Address verification of KIM
A1c
05 22 07
105-pg transcript of KIM interview
A1d
07 16 07
10-pg transcript of KIM interview #2
Ale
07 30 07
6-pg transcript Interview with Robert KIM
A2a
05 04 07
7-pg Investigative Plan
A2b
05 09 07
Agenda for Investigative Team meeting
A2c
05 10 07
Follow up to Meeting, case file information
A2d
05 17 07
Email from KING to Investigative Team - Update
A2e
05 22 07
A2f
06 12 07
A2g
06 20 07
A2h
06 27 07
A2i
06 29 07
A2j
06 29 07
Email from KING Draft Agenda and Updates
A2k
06 29 07
Draft Agenda
A2l
07 05 07
A2m
07 10 07
A2n
07 11 07
AGENDA
A2o
07 11 07
Email from LORANCE to MINNIS witness equity
A2p
07 20 07
A2q
07 30 07
A2r
08 02 07
A2s
08 07 07
A2t
08 08 07
A2u
08 13 07
A2v
08 14 07

Investigation #2
Page 23 of 302
1/16/2008

A2w
08 17 07
A2x
08 24 07
A2y
09 14 07
A2z
09 21 07
A2aa
09 27 07
A2bb
10 03 07
Email from KING to Investigative Team Meeting preparation
A2cc
10 05 07
A2dd
10 08 07
A2ee
10 11 07
A2ff
10 12 07
A2gg
10 18 07
A2hh
10 22 07
A2ii
10 29 07
A2jj
11 01 07
A2kk
11 07 07
A3a
05 01 07
2-pg letter from GIUSTO to MINNIS
A3b
05 07 07
2-pg letter from MCCAIN to MINNIS
A3c
10 05 07
Letter from KING to GIUSTO
A3d
10 01 07
107-pg transcript of Bernard GIUSTO interview
A3e
10 10 07
Certified Mail Return Receipt
A3f
11 01 07
2-pg Media speech - Giusto
A3g
11 15 07
Letter from MCCAIN to LORANCE
A3h
11 14 07
Affidavit of Bernard GIUSTO Investigation #1
A3i
71-pg Bernard GIUSTOs written response Investigation #1
A3j
11 21 07
3-pg letter from MCCAIN Standard of Proof
A4a
08 15 07
Email to/from MCCAIN/KING/TWEEDT
A5a
06 28 07
Email from KING to OCONNELL (LEDS)
A5b
06 28 07
Email from OCONNELL(LEDS) to KING
A5c
07 02 07
Letter from MALIN to KING
A5d
06 30 07
LEDS Audit Search Results MCSO

Investigation #2
Page 24 of 302
1/16/2008

A5e
06 30 07
LEDS Audit Search Results DPSST
A5f
07 03 07
Memo from KING to MINNIS
A5g
06 30 06
LEDS Manual, Definitions
A5h
07 16 07
Letter from MINNIS to MALIN
A5i
07 16 07
Letter from MALIN to MINNIS
A6a
06 28 07
Email from KING to ANGLEMIER Legal research Statutory

Rape, mandatory reporting, statute of limitations
A6b
07 18 07
Memo from ANGLEMIER to KING Statutory Rape Research
A6c
08 23 07
Memo from ANGLEMIER to KING Follow up on Statutory Rape

Research
A6d
09 26 07
3-pg Email to/from KING/ANGLEMIER CHL statute ORS

166.291
A6e
10 03 07
Email from KING to ANGLEMIER Brady issues
A6f
10 09 07
Restraining Order Research Request
A6g
10 09 07
Email from ANGLEMIER to KING - GSPC
A6h
A6i
Truthfulness and Public Safety Professionals Court Decision

10 14 07
Email from KING to ANGLEMIER Sheriffs authority to issue

handgun license
A6j
10 14 07
Email from KING to ANGLEMIER Sex with a minor, when is this

a crime?
A6k
10 15 07
Memorandum from ANGLEMIER Criminal Conduct, as affected

by the statute of limitations
A6l
10 15 07
Memorandum from ANGLEMIER Concealed handgun licenses

statutory authority
A6m
10 18 07
Email to/from KING/ANGLEMIER corroboration interpretation
A6n
11 01 07
Email to/from KING/ANGLEMIER Additional allegation against

GIUSTO, referral to Government Standards and Practices
A7
04 30 07
4-pg DPSST Employee Profile - GIUSTO
A8
05 11 07
2-pg F100 Complaint Form and 6-pg supporting documents from

November 2004 - Driggs

Investigation #2
Page 25 of 302
1/16/2008

A9a
01 04 07
13-pg Report from Oregon Department of Justice(DOJ)
A9b
05 09 07
Letter from KING to MADDUX DOJ
A9c
05 11 07
Letter from TWEEDT DOJ to KING
A9d.1
10 11 05
8-pg DOJ interview of James JEDDELOH
A9d.2
10 20 05
5-pg DOJ interview of Cheryl PERKINS
A9d.3
10 20 05
5-pg DOJ interview of Timothy KALBERG
A9d.4
10 21 05
5-pg DOJ interview of Michael SCHRUNK
A9d.5
10 21 05
4-pg DOJ interview of Christopher LOUGHRAN
A9d.6
11 01 05
3-pg DOJ interview of Tim MUSGRAVE
A9d.7
11 08 05
3-pg DOJ interview of Brett ELLIOTT
A9d.8
11 08 05
5-pg DOJ interview of Marshall ROSS
A9d.9
11 08 05
3-pg DOJ interview of Jason GATES
A9d.10
11 10 05
3-pg DOJ interview of Ryan ENGWEILER and Kelly SHEIFFER
A9d.11
11 14 05
6-pg DOJ interview of Horst JEDDELOH and handwritten note
A9d.12
11 15 05
3-pg DOJ interview of Lee GRAHAM
A9d.13
11 15 05
2-pg DOJ interview of Jeanne BROWN
A9d.14
11 29 05
11-pg DOJ interview of Lee JEDDELOH
A9d.15
11 29 05
33-pg DOJ transcript of Lee JEDDELOHs interview
A9d.16
12 09 05
34-pg DOJ transcript of Bernie GIUSTOs interview
A9d.17
08 18 06
2-pg DOJ interview of Kathleen WALLIKER
A9d.18
08 18 06
2-pg DOJ interview of David RADER
A9e
07 03 07
Email from KING to TWEEDT two versions of JEDDELOH CHL

application
A9f.1
11 08 05
4-pg Report of Interview - ELLIOTT, JEDDELOHs CHL
A9f.2
02 04 05
Application with GIUSTOs handwritten note approving CHL
A9g.1
09 30 05
DOJ Action Report, JEDDELOHs CHL application without

GIUSTOs handwritten note approving CHL
A9g.2
09 29 05
Letter from GIUSTO to BRIGGS
A9g.3
02 04 05
MCSO Concealed Handgun License Application
A9g.4
02 04 05
MCSO Concealed Handgun License

Investigation #2
Page 26 of 302
1/16/2008

A9g.5
02 04 05
2-pg PPDS Complete Name Record
A9g.6
02 04 05
LEDS - JEDDELOH
A9g.7
02 04 05
LEDS - JEDDELOH
A9g.8
02 04 05
CCH - JEDDELOH
A9g.9
02 04 05
LEDS WANTS - JEDDELOH
A9g.10
02 04 05
NCIC WANTS - JEDDELOH
A9g.11
02 04 05
Triple I - JEDDELOH
A9g.12
02 04 05
Mental Health Check - JEDDELOH
A9g.13
02 04 05
Protection Order Check - JEDDELOH
A9g.14
02 04 05
NLETSS Check - JEDDELOH
A9g.15
02 04 05
DOCLink Response - JEDDELOH
A9g.16
02 04 05
LEDS - JEDDELOH
A9g.17
02 08 05
OJIN Report - JEDDELOH
A9g.18
02 08 05
Fax Cover to PPB from MCSO
A9g.19
02 08 05
Fax sent confirmation
A9g.20
02 08 05
Copies of Report sent to check list
A9g.21
07 18 04
3-pg Welfare Check Report
A9g.22
07 24 05
4-pg Threats Report
A9g.23
2-pg Supplemental Family Abuse Report
A9g.24
02 10 05
Fax received confirmation
A9g.25
07 23 04
6-pg DUII Custody Report with accompanying 5-pg documentation
A9g.26
02 10 05
Memo from BROWN to GRAHAM, with GIUSTOs approval
A9g.27
02 18 05
CCW Applicant Card Submitted
A9g.28
02 22 05
Action Suspended
A9g.29
05 18 05
Property Inventory Receipt
A9g.30
05 05 05
LEDS - JEDDELOH
A9g.31
06 27 05
124-pg transcript JEDDELOH v JEDDELOH
A9g.32
05 13 05
Letter and envelope from JEDDELOH to GIUSTO
A9h.1
12 27 05
Letter from Sowle to DOJ Investigator McBETH
A9h.2
04 29 05
Email from Lee Jeddeloh to Dr. NEFF

Investigation #2
Page 27 of 302
1/16/2008

A9h.3
04 29 05
Email from/to Lee JEDDELOH/GECKLER
A9h.4
04 29 05
3-pg Email to/from Lee JEDDELOH/Dianne
A9h.5
05 03 05
2-pg Email to/from Lee JEDDELOH/GECKLER
A9h.6
05 04 05
2-pg Email to/from Lee JEDDELOH/KALBERG
A9h.7
05 05 05
2-pg Email from Lee JEDDELOH to Dan WIEDEN
A9h.8
05 05 05
3-pg Email to/from Lee JEDDELOH/GECKLER
A9h.9
05 05 05
Email from Ashby to Lee JEDDELOH
A9h.10
05 05 05
A9h.11
06 22 05
2-pg Email from GIUSTO to Lee JEDDELOH
A9h.12
06 22 05
Email from ROSS to GIUSTO
A9h.13
04 29 05
Email from Lee JEDDELOH to NEFF
A9h.14
04 29 05
Email from Lee JEDDELOH to GIUSTO
A9h.15
04 29 05
3-pg Email from Lee JEDDELOH to GIUSTO
A9h.16
05 03 05
2-pg Email from Lee JEDDELOH to GECKLER
A9h.17
05 04 05
2-pg Email from Lee JEDDELOH to KALBERG
A9h.18
05 05 05
2-pg Email from Lee JEDDELOH to WIEDEN
A9h.19
05 05 05
3-pg Email from Lee JEDDELOH to GIUSTO
A9h.20
05 05 05
A9h.21
05 05 05
A9h.22
06 22 05
A9h.23
06 22 05
Email from ROSS to GIUSTO
A9i.1
12 27 05
Email from MCCAIN to McBETH
A9i.2
12 27 05
3-pg letter from GIUSTO to McBETH
A9i.3
06 29 06
2-pg letter from McINTYRE to PELLEGRINI
A9i.4
04 04 05
Email from GIUSTO to Lee JEDDELOH
A9i.5
06 27 05
2-pg email from GIUSTO to SORIANO
A9i.6
06 23 05
2-pg Email from GIUSTO to ROSS
A9i.7
06 13 05
A9i.8
07 27 05
A9i.9
08 28 05

Investigation #2
Page 28 of 302
1/16/2008

A9i.10
12 06 05
2-pg Email from GIUSTO to Shannon and Des
A9i.11
06 22 05
3-pg Email from GIUSTO to Ashby
A9i.12
02 22 06
2-pg Email from Nola to Lee JEDDELOH
A9j.1
10 24 05
DOJ Action Report Telephone records received
A9j.2
34-pgs telephone records
A10
7-pg OAR 259-008-0010
A11
9-pg OAR 259-008-0070
A12.a
20-pg media clipping recaps
A12.b
News Articles A12a.1 A12.119
A12.c
11 15 07
GIUSTO blasts the Oregonian media not the public
A13a
6-pg ORS 206.010 - .345
A13b
6-pg ORS 166.291
A14a
2006
63-pg Multnomah County District Attorney Independent Review
A14b
2006
Appendix
A14c
11 22 06
MCSO 58-pg response
A15a
06 11 07
9-pg complaint of Fred LEONHARDT
A15b
06 12 07
PARSONS handwritten note of Fred LEONHARDT interview
A15c
06 19 07
9-pg handwritten interview notes - KING
A15d
06 19 07
12-pg handwritten interview notes - PARSONS
A15e
06 11 07
9-pg Fred LEONHARDT complaint with question notations
A15f
06 19 07
57-pg transcript of Fred LEONHARDT interview
A15g
06 29 07
2-pg email to/from Fred LEONHARDT/KING
A15h
07 03 07
2-pg email from KING to Fred LEONHARDT follow up questions
A15i
07 03 07
2-pg email to/from KING/Fred LEONHARDT - transcript
A15j
07 03 07
7-pg email to/from KING/Fred LEONHARDT responses to follow

up questions
A15k
07 03 07
Email from KING to Fred LEONHARDT Draft Affidavit
A15l
07 03 07
8-pg Draft Affidavit Fred LEONHARDT
A15m
07 06 07
10-pg Affidavit Fred LEONHARDT
A16a
06 20 07
Email from NAITO to MINNIS with attached letter

Investigation #2
Page 29 of 302
1/16/2008

A16b
05 05 07
Memorandum from PAUGH to Local Public Safety Coordinating

Council
A16c
06 12 07
Parsons notes of interview with NAITO
A16d
08 06 07
Email from PARSONS to KING Interview with NAITO
A16e
08 09 07
22-pg transcript - Interview with NAITO
A16f
08 09 07
3-pg Memorandum from NAITO to NOELLE
A17a
06 21 07
Internet search of Tom GIUSTO
A17b
06 21 07
PARSONS handwritten note of GIUSTO contact
A17c
06 21 07
3-pg transcript of conversation with Tom GIUSTO
A17d
06 21 07
Email from PARSONS to KING, recap of conversation with

GIUSTO
A17e
07 24 07
Letter from KING to Tom GIUSTO
A17f
07 27 07
A17g
10 09 07
32-pg transcript of Tom GIUSTO interview
A18a
06 26 07
Email from MINNIS to KING
A18b
06 26 07
3-pg transcript of interview of Helen (Foster) BICART
A19a
06 29 07
Email from KING to GONZALEZ - YOUMANS
A19a.l
06 29 07
Email from KING to KARL
A19a.2
06 29 07
Email from KING to KARL
A19b
07 24 07
Letter from KING to YOUMANS
A19c
07 26 07
Certified Mail Returned forwarding address
A19d
08 08 07
Letter from KING to YOUMANS with Certified Mail return Receipt

new address on YOUMANS
A19e
08 08 07
5-pg transcript interview with YOUMANS
A20a
07 03 07
Email to/from KING/GONZALEZ
A20b
07 03 07
1-pg Email to/from KING/GONZALEZ
A20c
07 16 07
3-pg transcript of phone message to KENNEDY
A20d
07 18 07
26-pg transcript interview #1 of Debby (Stone) KENNEDY
A20e
07 20 07
16-pg transcript interview #2 of Debby (Stone) KENNEDY
A20f
08 24 07
Email to/from KING/TWEEDT confidentiality of witness

Investigation #2
Page 30 of 302
1/16/2008

A20g
08 24 07
Email to/from KING/KENNEDY
A20h
09 21 07
Email from KING to KENNEDY
A21a
06 26 07
Email from GONZALEZ to KING Margie GOLDSCHMIDT
A21b
07 24 07
Letter from KING to Margie GOLDSCHMIDT
A21c
07 16 07
Phone message, transcribed Margie GOLDSCHMIDT
A21d
07 26 07
3-pg transcript Margie GOLDSCHMIDT telephone message #1
A21e
07 26 07
3-pg transcript Margie GOLDSCHMIDT telephone message #2
A21f
07 27 07
A21g
07 30 07
44-pg transcript - Margie GOLDSCHMIDT interview
A22a
06 26 07
Email from GONZALEZ to KING Neil GOLDSCHMIDT
A22b
07 24 07
Letter from KING to Neil GOLDSCHMIDT
A22c
07 26 07
3-pg transcript Neil GOLDSCHMIDT telephone message
A22d
07 27 07
A22e
08 03 07
Email from PARSONS to KING business card left at

GOLDSCHMIDT residence
A22f
08 24 07
18-pg article on Neil GOLDSCHMIDT
A23a
08 13 07
43-pg transcript - Interview with Gregg KANTOR
A23b
06 26 07
Email from GONZALES to KING
A24a
08 06 07
22-pg transcript - Interview with Thomas IMESON
A24b
06 26 07
Email from GONZALES to KING
A25a
06 28 07
Email from KING to MCCAIN OTT
A25b
08 09 07
10-pg transcript- Interview with Jennifer OTT
A26a
06 28 07
9-pg transcript of conversation with MCCAIN
A27a
05 01 07
Email from MCCAIN to Minnis GIUSTO response to KIM (Ex

A3a)
A27b
05 07 07
Email from MCCAIN to MINNIS GIUISTOs response to LEDS

check (Ex A3b)
A27c
06 28 07
Email to/from MCCAIN to KING MCSO DA Response (Ex A14c)
A27d
06 28 07
Email to/from KING/MCCAIN MCSO Org Chart and SOP

(ExA28)

Investigation #2
Page 31 of 302
1/16/2008

A27e
06 28 07
Email to/from KING/MCCAIN MCSO Corrections/OTT
A27f
07 02 07
Email to/from KING/MCCAIN MCSO SIU
A27g
07 10 07
Email to/from KING/MCCAIN Contact information
A27h
07 17 07
Email to/from KING/MCCAIN Margie Goldschmidts brothers
A27i
07 24 07
Email to/from KING/MCCAIN Gresham employee
A27j
07 26 07
Email to/from KING/MCCAIN Interviews (period of 07/24

07/26)
A27k
07 27 07
Email to/from KING/MCCAIN Interviews (period of 07/24

07/27)
A27l
07 30 07
Email to/from KING/MCCAIN Female Volunteer Chaplain
A27m
07 30 07
Email to/from KING/MCCAIN Harassment/Discrimination Policy
A27n
07 31 07
Email to/from KING/MCCAIN Email addresses
A27o
07 31 07
Email to/from KING/MCCAIN KIM complaint 2.b.
A27q
07 31 07
Email to/from KING/MCCAIN - Interviews
A27r
08 01 07
Email to/from KING/MCCAIN KIM complaint 2.c.
A27s
08 01 07
Email to/from KING/MCCAIN KIM complaint 2.a.
A27t
08 01 07
A27u
08 01 07
Email to/from KING/MCCAIN Dianna Olsen
A27v
08 01 07
Email to/from KING/MCCAIN KIM complaint 2.b.
A27w
08 03 07
Email to/from KING/MCCAIN Brent Ritchie
A27x
08 09 07
Email to/from KING/MOYER - Interviews
A27y
08 10 07
Email to/from KING/MOYER Interviews (period 08/06 08/10)
A27 z
08 17 07
Email to/from KING/MCCAIN/TWEEDT revocation action on

Sheriff
A27aa
09 12 07
Email to/from KING/MCCAIN Giusto update
A27bb
09 12 07
A27cc
09 24 07
Email to/from KING/MCCAIN CHL JEDDELOH
A27dd
09 27 07
Email to/from KING/MCCAIN KIM complaint 5.c.
A27ee
10 02 07
Email to/from KING/MCCAIN update on next process
A27ff
10 05 07
Email from MCCAIN - Sulzberger

Investigation #2
Page 32 of 302
1/16/2008

A27gg
10 11 07
Letter from KING to MCCAIN returning confidential employee

information
A27hh
10 12 07
Email from KING to MCCAIN Public Records Request
A27ii
10 12 07
Email from MCCAIN to KING response and attachments
A27jj
10 19 07
Email to/from KING/MCCAIN follow up on discussion, extension
A27kk
10 20 07
Faxed letter from MCCAIN to KING legal representation of

GIUSTO, Original and envelope
A27ll
10 17 07
Certified Mail return Receipt
A27mm 10 26 07
Memo to file, Request for Exhibits
A27nn
10 08 07
Exemption from Disclosure
A27oo
10 12 07
Email to/from KING/MCCAIN public information request
A27pp
10 30 07
Email from KING to MCCAIN referral to LORANCE
A27qq
11 02 07
Email from/to MCCAIN/KING Exhibit number
A27rr
11 05 07
Email from/to MCCAIN/KING Interview dates
A27ss
11 07 07
Email from MCCAIN to BUDNICK, response from MINNIS

Instructor issues
A27tt
01 09 08
Email from/to McCAIN/KING
A27uu
01 09 08
Memorandum from LORANCE to McCAIN
A28a
06 28 07
Email from KING to MCCAIN MCSO SOP
A28b
245-pg MCSO Agency Manual
A29a
07 05 07
LEONHARDT handwritten note about appointment book entry
A29b
12 02 94
Copy of appointment book - Christy LEONHARDT
A29c
07 05 07
Envelope from LEONHARDT to KING
A29d
07 17 07
29-pg transcript of interview Christy LEONHARDT
A29e
07 27 07
4-pg email to/from KING/Christy LEONHARDT - Affidavit
A29f
07 25 07
Fax Cover from Christy LEONHARDT to KING
A29g
07 30 07
7-pg Affidavit of Christy LEONHARDT
A30a
07 09 07
2-pg email from KING to SIMMONS
A30b
07 10 07
Memo to file KING Conversation with YORK
A30c
07 30 07
2-pg Polygraph Examination Report Fred LEONHARDT

Investigation #2
Page 33 of 302
1/16/2008

A31a
07 12 07
Email to/from KING/GONZALEZ Ruth Ann DODSON
A31b
07 25 07
Letter from KING to Ruth Ann DODSON
A31c
07 27 07
A32a
07 12 07
Email to/from KING/GONZALEZ James JEDDELOH
A32b
08 06 07
8-pg transcript - Interview with JEDDELOH
A32c
01 05 06
3-pg Clackamas County District Attorney memorandum on

JEDDELOH incident
A33a
07 24 07
Email from VANMETER to KING Jacquenette McINTIRE
A33b
10 13 07
McINTIRE Memorandum to file
A33c
07 25 07
Letter from KING to McINTIRE
A33d
08 06 07
12-pg transcript - Interview with Jacquenette McINTIRE
A33e
07 30 07
Certified Mail Return Receipt - McINTIRE
A34a
07 16 07
18-pg Interview of Ed STELLE
A35a
07 24 07
2-pg letter from KING to KOK (OSP)
A35b
07 27 07
A35c
08 09 07
2-pg response from Oregon State Police
A36a
07 16 07
11-pg transcript telephone call to Todd SHANKS
A37a
07 17 07
44-pg transcript Interview #1 with Lee GRAHAM
A37b
08 09 07
7-pg transcript Interview #2 with Lee GRAHAM
A37c
09 24 07
Email from KING to GRAHAM - Affidavit
A37d
09 27 07
Affidavit of GRAHAM (faxed)
A38a
07 30 07
2-pg email to/from KING/MCCAIN Alice TATE
A38b
08 02 07
11-pg - Interview with Alice TATE
A39a
08 08 09
Contact information on Garr NIELSEN
A39b
09 27 07
Letter from KING to NIELSEN
A39c
10 04 07
22-pg transcript Garr NIELSEN
A39d
10 09 07
A40a
07 26 07
25-pg transcript Interview with Dave RADER
A40b
11 11 04
30-pg IA on Racial Slur/Discrimination RADER/CORTADA
A41a
07 26 07
6-pg transcript Interview with Marshall ROSS

Investigation #2
Page 34 of 302
1/16/2008

A42a
07 26 07
35-pg transcript Interview with Sean CHRISTIAN
A43a
07 26 07
24-pg transcript Interview with Deirdre McGILL
A44a
07 26 07
16-pg transcript Interview with Jason GATES
A45a
07 27 07
11-pg transcript Interview with Christine KIRK
A46a
07 27 07
18-pg transcript Interview with Rafael CORTADA
A47a
07 30 07
24-pg transcript Interview with Robert BURTCHAELL
A48a
07 30 07
22-pg - Interview with David YADEN
A49a
09 24 07
Email from PARSONS to KING Gresham City Council women
A50a
08 01 07
6-pg transcript - Interview of Roger WOOD
A51a
08 02 07
28 - Interview with Bobby ODONNELL
A52a
08 02 07
6-pg transcript - Interview with Jose TORRES
A53a
08 02 07
7-pg transcript - Interview with Tim WONACOTT
A54a
08 16 07
20-pg transcript - Interview with Senator BURDICK
A55a
08 09 07
13-pg transcript - Interview with Ned WALLS
A56a
04 06 05
152-pg IA on Diana OLSEN
A56b
10 03 05
58-pg Independent review of Diana OLSEN allegations
A56c
09 17 07
32-pg transcript - Interview with Diana OLSEN
A56d
08 12 07
2-pg email from HASLER to King OLSEN grievance
A56e
08 10 07
3-pg mail to/from KING/HASLER OLSEN grievance
A57a
08 13 07
8-pg transcript - Interview with Mark HERRON
A58a
08 13 07
10-pg transcript - Interview with Jay PENTHENY
A59a
08 09 07
19-pg transcript - Interview with Tim MOORE
A60a
08 13 07
17-pg transcript - Interview with Brent RITCHIE
A61a
08 09 07
9-pg transcript - Interview with Kathy WALLIKER
A62a
08 14 07
Letter from KING to BUDNICK
A62a.l
08 16 07
Certified Mail Return Receipt - BUDNICK
A62a.2
08 17 07
5-pg transcript of BUDNICK telephone interview
A62b
08 14 07
Letter from KING to SANDERS
A62b.l
08 16 07
Certified Mail Return Receipt - SANDERS
A62c
08 14 07
Letter from KING to STANFORD

Investigation #2
Page 35 of 302
1/16/2008

A62c.1
08 16 07
Certified Mail Return Receipt - STANFORD
A62d
08 14 07
Letter from KING to GEDDES
A62d.l
08 16 07
Certified Mail Return Receipt - GEDDES
A62e
08 14 07
Letter from KING to GREEN
A62e.l
08 16 07
Certified Mail Return Receipt - GREEN
A62f
08 14 07
Letter from KING to MAPES
A62g
08 14 07
Letter from KING to WILSON
A62g.l
08 16 07
Certified Mail Return Receipt - WILSON
A62h
08 14 07
Letter from KING to SULZBERGER
A62i
08 14 07
Letter from KING to WALTH
A62j
08 14 07
Letter from KING to ESTEVE
A62j.l
08 16 07
Certified Mail Return Receipt - ESTEVE
A62k
08 14 07
Letter from KING to ZAITZ
A62k.l
08 16 07
Certified Mail Return Receipt - ZAITZ
A62l
08 14 07
Letter from KING to JAQUISS
A62l.1
08 16 07
Certified Mail Return Receipt - JAQUISS
A62m
08 14 07
Letter from KING to VALDEZ
A62m.l
08 16 07
Certified Mail Return Receipt - VALDEZ
A62n
08 16 07
News clipping on media letters
A62o
08 17 07
Phone message from Theresa BOTTOMLY, Oregonian, transcribed
A63a
08 20 07
Letter from REESE to Lorance re: KULONGOSKI
A63b
08 22 07
2-pg letter from LORANCE to REESE re: KULONGOSKI
A63c
08 22 07
3-pg questions for KULONGOSKI
A63d
08 31 07
Cover letter and 5-page unsigned questions and responses, envelope
A63e
08 31 07
Email from LORANCE to Investigative Team Update
A63f
10 30 07
Letter from REESE to LORANCE KULONGOSKIs Affidavit
A63g
10 30 07
Affidavit of KULONGOSKI with copies of A63d
A64a
09 17 07
19-pg transcript Interview with Brett ELLIOTT
A65a
09 14 07
Letter from KING to GIUSTO (KIM)
A65b
09 24 07

Investigation #2
Page 36 of 302
1/16/2008

A65c
10 04 07
4-pg transcript of interview KIM GIUSTO
A66a
09 14 07
Letter from KING to HINKLEY
A66b
09 14 07
DMV Address Verification
A66c
09 21 07
Certified Mail Returned Non deliverable
A66d
09 27 07
Letter from KING to HINKLEY
A66e
09 24 07
Email from DOJ Watch Center to KING
A66f
10 02 07
Certified Mail return Receipt
A66g
10 04 07
19-pg transcript of interview - James HINKLEY
A67a
09 14 07
Letter from KING to GEISTWHITE
A67b
10 02 07
A67c
09 14 07
DMV Address verification
A68a
09 14 07
Letter from KING to BRANT
A68b
09 20 07
A69a
09 27 07
Letter from KING to BUTTS
A69b
10 04 07
A69c
10 03 07
Email to/from BUTTS/ KING
A69d
10 04 07
Email from BUTTS to KING
A70a
09 27 07
Letter from KING TO NOAH
A70b
10 02 07
A70c
10 04 07
5-pg transcript of interview Debby NOAH
A71a
09 27 07
Letter from KING to THOMPSON
A71b
10 01 07
A71c
10 04 07
4-pg transcript of interview Vicky THOMPSON
A72a
09 26 07
Email to/from KING/DOSS
A72b
10 01 07
18 pg transcript of interview with Lee DOSS
A72c
09 28 07
Email to/from KING/PARSONS/DOSS
A72d
11 16 07
Email from DOSS to LORANCE, Affidavit, fax cover
A73a
10 13 07
Telephone analysis of phone records of Lee DOSS
A73b
10 14 07
Telephone analysis of DOSS phone records, pre-intervention
A73c
10 13 07
Telephone call to Hotels of the World - transcribed

Investigation #2
Page 37 of 302
1/16/2008

A73d
10 13 07
Telephone call to Four Seasons Hotels and Resorts - transcribed
A73e
10 13 07
Telephone call to Fairmont Olympic Hotel - transcribed
A74a
June
38-pg transcript of Victoria Taft interviewing Giusto
2004
A75a
A75b
Legislative Audio and Video website print-out

11 17 04
17-pg transcript of Giusto testimony for reappointment to the TriMet Board
A76a
10 30 07
10-pg transcript of Lars Larson Show MCCAIN as Giustos

attorney
A77a
11 01 07
A78
39-pg transcript of Senator Vicki Walker

Duplicate of prior exhibit
A79
01 04 08
3-pg Email to/from McCAIN/BENTZ
A80
12 28 07
2-pg letter from Oregon State Bar to Lars Larson

Investigation #2
Page 38 of 302
1/16/2008

F. ALLEGATIONS
1. Summary Table
1.
2.
3.
4.
Allegation
Giusto failed to use outside investigators to investigate racial harassment
Giusto failed to investigate the conduct of a law enforcement sergeant involved
with another members wife
Giusto instigated a misuse of a leave complaint against a female sergeant
Had knowledge of GOLDSCHMIDTs crime and did not report it
5.
GIUSTOs statements to the public, in 2004 and later, about his knowledge, or
the extent of his knowledge, of the Goldschmidt crime are in conflict with
statements obtained during the course of the investigation.
6. Giusto had improper contacts with Margie GOLDSCHMIDT
7. Giusto had inappropriate relationship with a female Gresham City
Councilwoman while he was the Chief of Gresham Police Department.
8. Giusto had inappropriate communications with a female subordinate which
resulted in threats to her.
9. Giusto had inappropriate relationship with a female volunteer Chaplain which
affected a male Chaplain, an employee.
10. Giusto pursued a female PPB employee at a retirement dinner
11. Giusto inappropriately approved JEDDELOHs concealed handgun license
12. GIUSTOs statements to the public, in 2005 and 2007, and regarding his
knowledge of JEDDELOHs DUII diversion and domestic violence incident
are in conflict with statements made to DOJ investigators and physical
evidence obtained during the course of the investigation.
13. Giusto altered, or had altered, JEDDELOHs concealed handgun license
application and/or file
14. Giusto misused the protective order that Lee (Jeddeloh) DOSS obtained by
threatening Jim JEDDELOH.
15. Giusto engaged in a personal relationship with DOSS in an efforts to conceal
his previous bad acts; the issuance of the CHL
16. Giusto violated agency policy by sending numerous emails to DOSS from his
work computer.

Investigation #2
Page 39 of 302
1/16/2008
Finding
Admin closure; does not constitute misconduct for purposes of DPSST
standards
standards
Admin closure; the allegation is false
standards.
Referred to PPC
Admin Closure; not in DPSSTs jurisdiction

Admin closure; the allegation is false.
standards
Admin closure; the allegation is false.
standards
admin closure; does not constitute misconduct for purposes of DPSST
standards
Referred to PPC
Admin closure; the allegation is false

standards
standards
standards
17. GIUSTOs statements to the public in 2005, and in a 2006 deposition regarding
a trip to Seattle with Lee DOSS while her husband was in rehabilitation, are in
conflict with statements he made to DPSST.
Part A: GIUSTO was untruthful with the media, regarding a trip he took to Seattle
with Mrs. JEDDELOH while her husband was in rehabilitation.
Part B: GIUSTO was untruthful with the media when he stated he had not offered
Lee JEDDELOH $10,000 to pay for her husbands rehabilitation.
Part C: GIUSTO was untruthful with the media when he stated he had not been
involved in the planning of the intervention until the night before or maybe two
days before
18. Giusto has a loss of public confidence, and the Board of Multnomah County
Commissioners failed to determine if moral fitness issues would disqualify
him.
19. There is a perceived political connection between GIUSTO, KULONGOSKI
and DOJ.
20. Giusto improperly appeared in uniform to campaign for KULONGOSKI.
21. Giusto demonstrated poor management as shown by the Investigative Report
conducted by the MCDA
22. Giusto failed to maintain a high ethical standard, and therefore his subordinates
have engaged in similar conduct that has led to some arrests
23. Giusto has been publicly humiliated through the media
24. Giusto improperly directed his staff to check KIM in LEDS
Reference Findings definition page 10

Investigation #2
Page 40 of 302
1/16/2008
PART A: Refer to Police Policy Committee
PART B: Administratively close
PART C: Administratively close
Admin closure; not in DPSSTs jurisdiction
Admin closure; not in DPSSTs jurisdiction

standards
Admin closure; not within DPSSTs jurisdiction
Admin closure; there is no way to prove or disprove the allegation
standards
standards
2. Allegations Itemized
1)
Allegation 1: GIUSTO failed to use outside investigators to investigate racial

harassment.
In his interview, KIM asserted that Lieutenant Long made insensitive remarks about
being Oreo. KIM asserted that there was no investigation, and GIUSTO just squashed
it.19
The investigative team determined that there is not, nor has there been in the recent past,
a Lieutenant Long associated with MCSO.
The investigative team determined that the complainant was Deputy Rafael CORTADA,
and the subject of the complaint was Lt. Dave RADER. RADER told investigators that
he was speaking at a roll call about officer safety and related an incident which happened
to him. RADER described responding to a disturbance in which an African American
confronted him and was threatening. After back-up arrived, RADER, and other deputies
and fire personnel, restrained the individual between two backboards, like an oreo
cookie.20
According to CORTADA, who grew up back east, oreo is a derogatory term to
describe a mixed race individual.21 CORTADA told investigators that prior to the
referenced roll call he was seeking a promotion to sergeant and had been working on
areas that RADER, among other command staff, had identified as necessary for
promotion. At the referenced roll call, CORTADA offered a suggestion that would have
allowed him to fulfill one of the areas of growth. CORTADA related that RADER
discounted his suggestion and shortly thereafter related the incident described above.
Based on the totality of circumstances, CORTADA found RADERs usage of the
terminology offensive, but recognized that [RADER] didnt necessarily think he knew at
the time that he offended me.2223
Although CORTADA did not address the issue with RADER at that roll call with
RADER, he later told others about his feelings and ultimately this incident resulted in an
internal investigation.
RADER related that when he was made aware of CORTADAs concern, he wanted to go
to him and apologize but because the Union was involved, Chief Deputy GRAHAM told
him that he was not allowed to do so. At a later time, however, RADER did meet with
19
Ex A1c, pg 15-16
Ex A40a, pg 10
21
Ex A46a, pg 7
22
Ex A46A, pg 14
23
Ex A46a
20

Investigation #2
Page 41 of 302
1/16/2008

CORTADA, GRAHAM and GIUSTO and made his apologies. RADER stated that they
shook hands and he believed the matter was closed.
CORTADA also recalled a meeting with RADER in which RADER apologized. At issue
for CORTADA was that the investigation was not conducted by an outside investigator,
as per MCSO policy 6.07.
MCSO Pre-Investigative Assessment shows the incident occurred November 11, 2004
and that the complaint was received on November 15, 2004.24
On November 15, 2004, Captain Brett ELIOTT met with CORTADA to discuss his
concerns and documented his conversation.
On November 16, 2004, GRAHAM met with RADER. During their discussion of this
issue, RADER expressed the desire to apologize to CORTADA in person, but he was
asked to refrain until the matter had been referred to IAU.
On November 24, 2004, Sgt. Eric SMITH, MCSO IA Unit, interviewed CORTADA.
CORTADA related his concerns and the roll call event. When asked, SMITH advised
CORTADA that a future meeting would determine whether the matter would be assigned
to a formal Internal Investigation or whether it would be referred to the Chief Deputy or
some other appropriate action.
On November 29, 2004, CORTADA provided a written explanation of his concerns
about RADERs use of the terminology oreo. In his explanation, CORTADA
combined those concerns with the manner in which he perceived RADER discounted a
suggestion he had made. The impact of this, according to CORTADA, was significant to
him because he was working on areas of improvement to be a viable candidate for an
upcoming sergeants promotional opportunity. Additional concerns included RADERs
identifying the individuals race while relating an experience with the individual, and that
in CORTADAs personal experience, on the east coast, oreo is a derogatory term.
Based on the totality of circumstances, CORTADA was offended. The recommendation
was that the investigation be handled by a private, outside attorney. An additional note
indicated, Per Sheriff, complaint to be handled by Chief Deputy Lee Graham.25
On March 9, 2005, four months after the incident, Sheriff GIUSTO wrote a memo to file
indicating that he had met with CORTADA and with RADER. During this meeting
GIUSTO acknowledged that the process was unnecessarily delayed. GIUSTO noted that
RADER had apologized to CORTADA and had explained that he was unaware the term
oreo would be offensive to anybody. GIUSTO then related that RADER asked
CORTADA to accept his apology, that CORTADA directly accepted RADERs apology
and that both shook hands.26
24
Ex A40b
Ex A40b
26
Ex A40b, pg 2
25

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The investigative team determined that this matter was investigated internally. This
investigation did not follow MCSO policy. During an interview with NAITO, she stated
that she became aware of the incident when the leadership of the Union came to her and
she responded by forwarding the information to her county counsel27.
(cross-reference page 131, Cortada Interview Summary)
(cross-reference page 148, Giusto Interview Summary)
(cross-reference page 217, Rader Interview Summary)
Investigative Team Discussion: DPSST considered this allegation, to the extent of
determining if the allegation had substance and if so, if it was within DPSSTs
jurisdiction.
During the October 1, 2007 interview, GIUSTO stated he considered the issue, the intent
on why the issue had been brought and that he believed it was best addressed both
internally and directly face to face with the employees. GIUSTO stated that as the
Sheriff, it is under his purview to make those decisions.
As an elected official responsible for administering his own agency, Giusto has the
authority to set and modify policy, and has broad discretion in defining and exercising
his duties, (Ref ORS 206.010 206.345) (emphasis added)
Investigative Team Findings:
Administrative Closure; does not constitute misconduct for purposes of DPSST
standards.
27
Ex A16e

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2)
Allegation 2: GIUSTO failed to investigate the conduct of a law enforcement

sergeant involved with the wife of another member.
KIM provided no specific information on this allegation.

The investigative team determined that the law enforcement sergeant was Sgt. Brent
RITCHIE. Bobby ODONNELL, the husband of Laura ODONNELL, the female with
whom RITCHIE became romantically involved, was interviewed and stated that he has
been assured by both his former wife and by RITCHIE that their relationship did not
begin until after his divorce was final.28 ODONNELL stated at one point that he
believed that RITCHIEs certification should have been revoked for lack of integrity
becuse RITCHIE was one of his peer supporters prior to and during his divorce.
OCONNELL stated he has moved on and his relationship with RITCHIE is a
professional one.29
When interviewed, RITCHIE stated he did not engage in a relationship with Laura
ODONNELL until after the divorce was final.
(cross-reference page 217, ODONNELL Interview Summary)
(cross-reference page 217 RITCHIE Interview Summary)
Investigative Team Discussion: The investigative team considered this allegation, to the
extent of determining if the allegation had substance and if so, if it was within DPSSTs
jurisdiction.
RITCHIE was not a direct supervisor to ODONNELL. RITCHIE and ODONNELL
were working assignments in separate locations. The MCSO command staff was aware
of the situation and was monitoring it. RITCHIE and ODONNELL concur that MCSO
appropriately did not investigate this, due to the fact that this matter was not, and did not
become, an agency issue.30
There is no evidence that RITCHIEs actions occurred on duty or that he used agency
equipment in the furtherance of any misconduct.
Administrative Closure. This allegation does not constitute misconduct for purposes of
DPSST standards. This allegation is outside of DPSSTs jurisdiction.
28
Ex AA60a
Ex A51a
30
Ex A51a,A60a
29

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3)
Allegation 3: GIUSTO instigated a misuse of leave complaint against a female

sergeant, which was ultimately overturned.
KIM alleged that a female sergeant was reprimanded for something that she did not do
because someone did not like her. In his interview KIM further asserted that the female
filed a grievance with the union and hired a female attorney. KIM asserted that it was
not her fault. In his written complaint KIM asserted that GIUSTO instigated a misuse
of leave complaint against the female sergeant.
The investigative team determined that the female sergeant was Sergeant Diana OLSEN.
It appears that Lt. RADER, not GIUSTO, identified issues involving OLSEN and her
usage of time. The first incident occurred in 2003; its focus was on the amount of leave
an individual may use. In that instance Olsen filed a grievance and MCSO responded to
the grievance affirming their position, relying on contractual language relating to efficient
operations. The second incident occurred in 2005 and after an internal investigation was
completed on April 6, 2005, the incident resulted in a sustained finding of Violation of
Sick Leave, Reporting and Recording.31
Later, MCSO elected to hire an independent and outside review of issues relating to
OLSEN and her claims of disparate treatment based on her gender and economic status.
Ultimately a command review of the Independent Inquiry resulted in findings that read in
part, Ms. Saul did not find substantial evidence in any of the nine areas of concern to
conclude that there are instances or patterns of discriminatory behavior based on gender
or because she is financially well off. . . . While staggeringly expensive, the Inquiry puts
to rest all of the issues personally identified by Sergeant Olsen and addressed by Ms. Saul
with each witness. 32
(cross-reference page 217, OLSEN Interview Summary)
(cross-reference page 217 RADER Interview Summary)
Investigative Team discussion: The investigative team considered this allegation, to the
extent to determine if the allegation had substance and if so, if it was within DPSSTs
jurisdiction.
KIMs allegations fail on several points. It was RADER, not GIUSTO, who identified
potential misconduct by OLSEN. The allegation against OLSEN for violation of sick
leave was sustained. And it was MCSO, not OLSEN, who hired a female attorney to
investigate OLSENs assertions of disparity in how she was treated. The subject of this
investigation was not the allegation regarding violation of sick leave, which had been
sustained.
Administrative closure; the allegation is false.
31
32
Ex A56a
Ex A56b

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4)
Allegation 4: GIUSTO had knowledge of GOLDSCHMIDTs crime against a child

and did not report it.
Investigative Team Discussion:

Through research, the Investigative Team has formed the opinion that although
GOLDSCHMIDT clearly committed the crime of statutory rape, GIUSTO did not have a
legal obligation to report the crime if he knew about it in 1989. The mandatory abuse
reporting law was passed in 1993. Through research, the Investigative Team has formed
the opinion that GOLDSCHMIDTs crime was beyond the then current statute of
limitations.
In his 2004 testimony before the Senate Rules Committee, GIUSTO testified that his
reason for not reporting GOLDSCHMIDTs crime was that he believed that the statute of
limitations had expired when he learned of the crime.33 From this testimony, the
Investigative Team concludes that GIUSTO was aware that the elements of the crime of
statutory rape had occurred, because knowledge of those elements would have been
required for him to:
1. determine that the statute of limitations precluded prosecution, thereby
acknowledging he recognized Goldschmidt's behavior as a
crime
2. determine that he was not under obligation to report, based on the statute of
limitations for that crime.
At the time GIUSTO would have made the determination that the statute of limitations
had run the statute of limitations for all felonies was three years.34 (Based on statements
of LEONHARDT and KENNEDY, the Investigative Team has determined the timeframe
to be the fall of 1989)
However, GIUSTO could only rely upon this reasoning if he were certain of the
following specific factors:
1. That the victim was underage, and that the conduct therefore constituted a crime
2. When the crime had occurred
3. That he had knowledge of the statute of limitations, based on the elements of the
crime35
(cross-reference Allegation 5, page 48)
Although GIUSTO asserts that the rumor of GOLDSCHMIDTs crime was well known,
GIUSTOs OSP partner with the governors security detail, James HINKLEY, stated that
33
Ex A74b, p 8, 9
Ex A6c
35
Ex A6b, 6c
34

Investigation #2
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he had never heard any such rumor.36 When asked by investigators if HINKLEY would
have reported the rumor, he stated, Without a doubt . . . .ethically I thought it was
appropriate . . . it would have been my responsibility to pass it along . . .a concern with
the governor being around young people . . .37
Administrative Closure. Because GOLDSCHMIDTs crime was beyond the statute of
limitations, and because there was no mandatory reporting obligation on the part of
GIUSTO, his conduct does not constitute misconduct for purposes of DPSST standards.
36
37
Ex A66g, p 11
Ex A66, P 12

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5)
Allegation 5: GIUSTOs statements to the public, in 2004 and later, about his
knowledge, or the extent of his knowledge, of the Goldschmidt crime are in
conflict with statements obtained during the course of the investigation.
Investigative Team Discussion
At issue is what GIUSTO knew, when he knew it, and whether GIUSTOs
statements to the public accurately represented his knowledge.
The investigative team considered the public to include the citizens of Oregon, the
media, and the 2004 Senate Rules Committee members before whom GIUSTO
testified.
Investigative Team Research
Relevant Public Statements:
On June 13, 2007, Brent Walth and Jeff Mapes of The Oregonian reported,
Giusto told the Oregonian that he doesnt remember talking specifics with
Leonhardt but may have discussed vague rumors in 1989 . . .38
On June 18, 2004, Phil Stanford of The Portland Tribune reported, Giusto
was saying this week he didnt know about the substance of the story until he
read it in the papers . . . before that it was just a rumor. When youre in law
enforcement you hear a lot of rumors. If you followed up on all of them you
wouldnt have time to do anything else.39
On June 18, 2004, Jim Redding of The Portland Tribune reported, Giusto
says he cannot recall hearing any rumors about Goldschmidt and an underage
girl even though he was romantically involved with the governors wife,
Margie, during that time.40
On June 24, 2007, Arthur Sulzberger of The Oregonian reported, Giusto, in
his second term as sheriff, has provided differing accounts concerning how
much he knew about Goldschmidt and the girl. He has admitted to hearing
rumors but denied knowing concrete facts. It was all very vague some gal,
some time, some place he told The Oregonian in 2004, describing a
conversation with Leonhardt.41
During another contact with the media, in a June, 2004 radio talk show with
Victoria TAFT for which a transcript is provided, she quoted from the
38
Ex A12.99
Ex A12.98
40
Ex A12.97
41
Ex A12.6
39

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Oregonian that, He [GIUSTO] doesnt remember talking specifics with
Leonhardt, but may have discussed vague rumors in 1989. He also said that
he was aware of potential legal settlement between Goldschmidt and his victim
around 1994, and that he may have talked to Leonhardt about it., TAFT
asked, Did you say that to the Oregonian? GIUSTO stated, Thats what I
said.42 GIUSTO denied telling LEONHARDT specific details because I
didnt have them.43 GIUSTO repeatedly relied upon having no independent
recollection.44 GIUSTO admitted to dating Margie GOLDSCHMIDT but did
not reference a timeframe.45 GIUSTO asserted that he had told the Oregonian
the first time I heard about it was when I knew she had to reopen the divorce
for some kind of civil settlement.46 Regarding his conversation with
LEONHARDT, GIUSTO later stated I had no detail that was meaningful
enough for him to make these kinds of claims. I never had that kind of detail .
. .47 I didnt tell him the kind of facts hes alleging.48. When TAFT asked
GIUSTO why LEONHARDT would pick GIUSTO out of everybody in the
whole wide world to pin this on and asked what does he [LEONHARDT]
have against you? GIUSTO stated, I dont think he has anything against
me.49
During a November 17, 2004 meeting of the Senate Interim Rules and
Executive Committee, while considering the reappointment of Bernie Giusto to
the Tri Met Board, Senator Vicki WALKER identified an August 6, 2004
meeting she had with GIUSTO. GIUSTO stated that he didnt come to the
campaign until 1986 and the statute of limitations probably ran 70 1971
no- or excuse me 1981 or 1984, depending on how you would like to qualify
it under past law or current law that the legal responsibility for anybody to
report it had long since past.50 GIUSTO then stated, . . .in my tenure with the
former governor and all my time around in the two years I sat in that
administration51, I never saw anything that would lead me to believe there were
other victims of anything.52
On November 1, 2007, investigators interviewed Senator WALKER.
WALKER said she and GIUSTO met, prior to his reelection to the Tri Met
Board, because WALKER was concerned about what GIUSTO knew of the
GOLDSCHMIDT crime and when he learned of the crime. GIUSTO told
WALKER he had not met or talked to the victim and that his only obligation
42
Ex A74a, p 6
Ex A74a, p 14
44
Ex A74a, p 13
45
Ex A74a, p 15
46
Ex A74a, p 16
47
Ex A74a, p 21
48
Ex A74a, p 24
49
Ex A74a, p 25
50
Ex A75a, p 8
51
Giusto was around the Goldschmidt administration from November 1986 to January 1989
52
Ex A75a, p 9
43

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was to find other victims.53 GIUSTO characterized his knowledge as a
rumor54 When asked if, in WALKERs mind, GIUSTO was acknowledging
that the rumor was legitimate, WALKER stated, . . .if hes thinking about
finding other victims, then there must have been one victim. 55 WALKER
went on to surmise that in order to determine the statute of limitations
GIUSTO must have known the approximate age of the victim when the abuse
had occurred.56 WALKER confirmed that after the news broke about the Neil
GOLDSCHMIDT crime she spoke with LEONHARDT and he knew the
victims name and told her; a fact that had not been in the media.57
Relevant Investigative Interviews

GIUSTOs statements are in conflict with Fred LEONHARDTs assertions that
in the fall of 1989 GIUSTO provided him details of GOLDSCHMIDTs crime.
Those details included knowing GOLDSCHMIDT raped his childrens
babysitter, the name of the victim, the age of the victim (14), the time frame
when the crime was committed (when GOLDSCHMIDT was Mayor of
Portland), and that GOLDSCHMIDT was using staff members as go betweens
to provide cash payments to the victim.58 Leonhardt also asserted that he had a
conversation with GIUSTO in 1994 in which GIUSTO shared updated
information about a monetary settlement with the victim. LEONHARDT said
GIUSTO told him that he had learned from Margie GOLDSCHMIDT that the
GOLDSCHMIDTs divorce papers were being unsealed, that there were
discussions regarding finances and that the information would be published in
the media. Leonhardt signed an Affidavit attesting to his assertions.59
LEONHARDT also successfully passed a polygraph based on his sworn
statement.60 (cross-reference H.69)
LEONHARDTs assertions are corroborated by his wife, Christy
LEONHARDT, who said Fred LEONHARDT told her what GIUSTO had told
him the day he learned the information from GIUSTO. 61 Christy
LEONHARDT did not recall when she first heard the victims name62 but
asserted that her husband told her GIUSTO told him the crime occurred when
GOLDSCHMIDT was the mayor that he had a sexual relationship with an
underage girl, and that the victims mother was active in politics.63 Christy
53
Ex A77a, p 11
Ex A77a, p 19
55
Ex A77a, p 21
56
Ex A77a, p 22
57
Ex A77a, p 29
58
Ex A15m, p 3-5, A15f,p 17
59
Ex A15m
60
Ex A30c
61
Ex A29d, p 15
62
Ex A29d, p 21
63
Ex A29d, p 20
54

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LEONHARDT asserted that Fred LEONHARDT told her he went to his
supervisor, Greg KANTOR, with the information. Like Fred,64 Christy
LEONHARDT also recalled a later party after which Fred LEONHARDT told
her he had learned additional information about the GOLDSCHMIDT issue.
Christy LEONHARDT said her husband related to her that GIUSTO told him
Margie GOLDSCHMIDT was having to open her divorce agreement to
convince the victims attorneys that Neil GOLDSCHMIDT did not have
enough money to pay off the victim. 65 Christy LEONHARDT signed an
Affidavit attesting to her assertions.66 (cross-reference H.67)
LEONHARDTs assertions are also corroborated by Greg KANTOR, who told
investigators that LEONHARDT came to him and shared what he said
GIUSTO had told him. KANTOR stated, So Fred tells me that he had heard
from Bernie that Neil had had sex with an underage girl. I cannot remember
when exactly that was. But I - - I have no doubt that Freds recollection is
probably right about the timing. He was probably correct.67 KANTOR then
stated, . . . he [Fred] did tell me that Bernie told him that Neil had had sex
with an underage girl, and I didnt believe him at the time. I dont think Fred
believed it at the time.68 KANTOR told DPSST investigators that
LEONHARDT told him in 198969 that GOLDSCHMIDT had sex with an
underage girl.70 KANTOR described LEONHARDT as shocked, and that
they couldnt believe it. KANTOR thought that LEONHARDT told him that
the crime occurred when GOLDSCHMIDT was the mayor.71 . (crossreference H.52)
LEONHARDTs assertions are also corroborated by Ginny BURDICK who
asserted that LEONHARDT shared specific details about what he said he had
learned from GIUSTO. A June 13, 2004 Oregonian article stated that
BURDICK and LEONHARDT met for coffee the day before
GOLDSCHMIDTs admission.72 LEONHARDT recalls the meeting before
the article came out. In an interview with DPSST investigators, BURDICK
asserted that she and Fred LEONHARDT met after the Willamette Week story
was published, and that LEONHARDT told BURDICK he had learned of
GOLDSCHMIDTs crime while LEONHARDT was in the governors office
and that GIUSTO knew of the crime.73 BURDICK said she learned specific
details when she met with reporters at the Willamette Week prior to the
GOLDSCHMIDT story being published. When asked if BURDICK could
64
Ex A15m, p 6
Ex A29d, p 9 - 10
66
Ex A29g
67
Ex A23a, page 4, lines 18-22
68
Ex A23a, page 5, lines 6-8
69
Ex A23, p 18
70
Ex A23, p 4
71
Ex A23, p 23
72
Ex A12.99
73
Ex A54, p 5
65

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form an opinion regarding whether Fred LEONHARDT had prior specific
knowledge, BURDICK said that her sense was that, something had gone on
and people knew about it.74 BURDICK also told investigators that Debby
KENNEDY had told her about GOLDSCHMIDTs crime, I think she said
underage girl and that KENNEDY had learned of this information from
GIUSTO. BURDICK characterized KENNEDY as a person who tells the
truth.75 (cross-reference H.9)
LEONHARDTs assertions are also corroborated by Debby KENNEDY.
KENNEDY told DPSST investigators she first met GIUSTO in 1987.
KENNEDY said GIUSTO had come to her home and told her that
GOLDSCHMIDT had decided not to run for re-election [prior to
GOLDSCHMIDTs announcement in Feb 1990] because he [GIUSTO] told
me that Neil had this issue with this underage girl.76 In response to the
question of how old the victim was, KENNEDY stated, Way under age.
When asked if KENNEDY thought LEONHARDT was telling the truth about
what GIUSTO had told him, KENNEDY stated, Well, he [GIUSTO]certainly
told me.77 KENNEDY recalled, I remember the whole thing very, very
vividly.78 KENNEDY stated that it was at her house when GIUSTO told her
that GOLDSCHMIDT was not going to run for re-election. She recalled
GIUSTO saying, Part of its because this things going to come out about this
underage girl. But the other reason is because Im having an affair with
Margie.79 Investigators read to KENNEDY a quote LEONHARDT had made
about a previous remark KENNEDY had made to him. The quote was, She
[KENNEDY] said that while engaged in a relationship with GIUSTO in 1989,
he had told her the same story about GOLDSCHMIDT and the girl that he had
told me. KENNEDY confirmed that statement was true. Although
KENNEDY initially did not recall specifics about a conversation she had with
LEONHARDT after the GOLDSCHMIDT crime became public, she told
investigators in a second phone interview that she had called LEONHARDT
because she was worried about him. KENNEDY characterized GIUSTO as a
very dishonest man. . . a very gifted liar. . . (cross-reference H.54 and H.55)
LEONHARDTs assertions are not corroborated by KULONGOSKIs written
responses. KULONGOSKI responded, in writing, that he has known
LEONHARDT for over twenty years, and characterized their relationship as
friends during the GOLDSCHMIDT administration. KULONGOSKI wrote
that he has visited LEONHARDTs home occasionally over the course of ten
years, has gone on walks with LEONHARDT and his child, has attended social
functions at LEONHARDTs residence, has been to Beaver baseball games
74
Ex A54a, p 14
Ex A54a, p 7, 17
76
Ex A20, p 23
77
Ex A20, P E
78
Ex A20e, p 6
79
Ex A20e, p 7
75

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with LEONHARDT and has occasionally met him for a beer.
KULONGOSKI responded No when asked if LEONHARDT had shared
information with him about GOLDSCHMIDT having sexual intercourse with a
minor female. He responded N/A to follow up questions about any further
conversations regarding that issue with LEONHARDT. KULONGOSKI
responded No to the question about whether or not he (KULONGOSKI) had
responded to LEONHARDTs revelation about GOLDSCHMIDT with a
response similar to it might be true. KULONGOSKI also responded No in
reply to a question about whether he (KULONGOSKI) had told
LEONHARDT that GIUSTO might have had something on Neil.
KULONGOSKI acknowledged he attended several holiday parties at Margie
GOLDSCHMIDTs home but did not recall ever traveling with LEONHARDT
to those events. KULONGOSKI responded N/A in reply to a question
asking if he had a conversation with LEONHARDT prior to a winter 1994
party at Margie GOLDSCHMIDTs residence about what GIUSTO knew
about GOLDSCHMIDTs relationhip with a minor female. KULONGOSKI
responded N/A to a series of follow up questions about aspects of
conversations LEONHARDT asserted he had with KULONGOSKI before,
during and after that party regarding GOLDSCHMIDTs sexual relationship
with the minor. KULONGOSKI denied having follow-up phone conversations
with LEONHARDT about those same issues, typing no and N/A in
response to those questions. KULONGOSKI responded No when asked if
Debby KENNEDY ever told him about her knowledge of GOLDSCHMIDTs
sexual relationship with a minor female.
KULONGOSKI responded No on the question about whether GIUSTO had
ever told him of GOLDSCHMIDTs sexual relationship with a minor.
KULONGOSKIs response to the question about when he learned of
GOLDSCHMIDTs sexual relationship with a minor was that he learned of it
from his Chief of Staff the evening before the story broke in the media.80
LEONHARDTs assertion that GIUSTO knew about GOLDSCHMIDTs
abuse of a child was acknowledged as substantively accurate by Margie
GOLDSCHMIDT in her response to a question posed by investigators.
GOLDSCHMIDT was asked if GIUSTO knew, by the time Neil left the
position as Governorhe [GIUSTO] at least knew something about it at that
time? GOLDSCHMIDT responded, Yeah. Hehe acknowledges that he
did.
When interviewed, Margie GOLDSCHMIDT asserted that whatever Bernie
learned and whenever he learned it, it was so far past this event. . . there - - it
had - - it way past the statute of limitations. There was nothing that he could
have done about it.81 GOLDSCHMIDT stated she was not going to talk about
80
81
Ex A63d - g
Ex A21g, p 6

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what she may or may not have said to GIUSTO. GOLDSCHMIDT went on to
say, I dont know when he first heard about this. But I do believe that it was
well after he started working for Neil. GOLDSCHMIDT confirmed that she
and GIUSTO socialized with LEONHARDT.82 GOLDSCHMIDT stated that
she and GIUSTO were together for 15 years.83
Investigators sent an inquiry to the Oregon State Police about GIUSTOs
tenure, assignments, promotion and policies relating to reporting crimes.84
OSP responded, indicating that because of the passage of time, there was
limited information. OSP was able to identify James HINKLEY and Richard
GEISTEWHITE as two troopers also assigned to the security detail along with
GIUSTO. Additionally, in that security detail, GIUSTO was to report to the
superintendent.85
Relevant Credibility Factors
GIUSTO has made a public assertion regarding his knowledge of
LEONHARDT.
Relevant Public Statement
On June 18, 2004, the Portland Tribune reported that GIUSTO stated about
LEONHARDT, I dont even know the guy. I talked to him maybe two times
in 15 years. Even if I knew something like that, I wouldnt just blurt it out to
someone I dont know.86
Relevant Investigator Interviews
GIUSTOs public disclaimers regarding his knowledge of LEONHARDT are
in conflict with what GIUSTO told DPSST investigators. GIUSTO stated he
first met LEONHARDT in approximately 1987 or 198887 when
LEONHARDT was the speechwriter for GOLDSCHMIDT. GIUSTO stated
he had met LEONHARDTs wife Christy, and their children.88 GIUSTO said
he knew where LEONHARDT lived and had been to their home on at least one
social occasion.89 GIUSTO described his relationship with LEONHARDT as
primarily in the context of his job on the governors staff.90 GIUSTO also
stated he had breakfast with LEONHARDT once in awhile together with
82
Ex A21g, p 12
Ex A21g, p 13
84
Ex A35a
85
Ex A35b
86
Ex A12.97
87
Ex A3d, p 10
88
Ex A3d, p 11
89
Ex A3d, p 12
90
Ex A3d, p 13
83

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other people, sometimes without.91 GIUSTO stated he also socialized with
LEONHARDT and his wife at Margie GOLDSCHMIDTs home. When
GIUSTO was asked if he had a conversation with LEONHARDT about
GOLDSCHMIDT having sex with a minor, GIUSTO stated yes. . . in
generalities. When GIUSTO was asked if he recalled a breakfast [in 1989] in
which he and LEONHARDT had a discussion about GOLDSCHMIDT
engaging in some misconduct with a minor female, GIUSTO stated, not as a
single topic.92 (cross-reference H.28) GIUSTO declined to sign an Affidavit
attesting to his assertions and declined to submit to a polygraph. GUISTO later
signed an affidavit attesting to his truthfulness in his responses to questions
posed by DPSST and DOJ investigators.
LEONHARDTs recollections include that in 1989 GIUSTO told him about
GOLDSCHMIDTs crime in specific detail. After the GOLDSCHMIDT era,
LEONHARDT said he and his wife Christy attended a 1994 holiday party at
Margie GOLDSCHMIDTs which GIUSTO co-hosted. LEONHARDT said
GIUSTO told him of a pending scandal to be released in the media and of
financial negotiations which included Margie GOLDSCHMIDTs divorce
papers being unsealed.93 Later, LEONHARDT described him and his wife
socializing with GIUSTO at a barbeque at Margie GOLDSCHMIDTs.94 And
finally, LEONHARDT described attending KULONGOSKIs inaugural
ceremony in 2003, where he and GIUSTO briefly spoke to one another.95
(cross-reference H.69) Leonhardt signed an Affidavit attesting to his
assertions and passed a polygraph based on his Affidavit.
In response to a complaint filed by Lars LARSON and James JOHNSON to
the Oregon State Bar, Assistant General Counsel Chris MULLMANN
addressed Governor KULONGOSKIs denial of learning of the relationship
[the GOLDSCHMIDT crime] and that LEONHARDT acknowledged that he
has no corroboration to support his recollection regarding KULONGOSKI.
MULLMANN noted that he gives little weight to the polygraph evidence [of
LEONHARDT] consistent with the treatment of polygraph evidence in a civil
or criminal trial or other legal proceeding subject to rules of evidence.
MULLMANN commented, I find that both Mr. Leonhardt and Governor
Kulongoski are credible in their recollections.96
91
Ex A3d, p 14
Ex A 3d, p 20
93
Ex A15m, p 6
94
Ex A15m, p 7
95
Ex A15m, p 8
96
Ex A80
92

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Investigative Team Analysis:
GUISTO made a public statement to the Portland Tribune which reported, he
didnt know the substance of the story until he read it in the papers. . . . before it
was just a rumor. Statements from witnesses asserting GIUSTO provided
substantive details of GOLDSCHMIDTs crime are in direct conflict with
GIUSTOs public statements that he had heard only rumors or had only minimal
knowledge of the crime.
GIUSTOs public statement to the Portland Tribune which reported Giusto says he
cannot recall hearing any rumors about Goldschmidt and an underage girl is in
conflict with GIUSTOs statement cited in the above paragraph.
Witness statements assert GIUSTO knew:
1. The victim was a female;
2. The victim was underage;
3. The crime was past the statute of limitations, thereby acknowledging
the conduct as criminal; and
4. The approximate timeframe of the crime so that he could formulate
an assessment that the statute of limitations had run.
GIUSTOs public statements to the 2004 Senate Rules Committee indicate he
acknowledged some merit in the rumors to the extent that he asserted, . . .in my
tenure with the former governor and all my time around in the two years I sat in that
administration, I never saw anything that would lead me to believe there were other
victims of anything.97 These statements establish when he knew ,since he tacitly
admits to keeping an eye on GOLDSCHMIDT when he worked for him, in order to
make an assessment regarding the potential risk to other victims. That statement is
also in conflict with GIUSTOs position that all he ever heard were vague
rumors98.
A number of individuals corroborate LEONHARDTs recollections on numerous
issues. KANTOR corroborated that LEONHARDT told him that GIUSTO had
shared information about GOLDSCHMIDTs crime after he had learned of it.
KENNEDY corroborated that GIUSTO also told her of GOLDSCHMIDTs crime.
BURDICK corroborated that KENNEDY told her that GIUSTO provided
KENNEDY with the same information. Christy LEONHARDT corroborated when
and what Fred LEONHARDT told her about GIUSTOs statements to her husband.
KULONGOSKIs responses to written questions do not corroborate
LEONHARDTs assertions.
97
98
Ex A75b, p 9
A12.99

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Based on Fred LEONHARDTs interview, KING prepared a Draft Affidavit99 which
was emailed100 to LEONHARDT to review and amend as needed to ensure it was an
accurate reflection of the interview and his recollections. LEONHARDT reviewed
and signed his Affidavit in the presence of a notary.101 LEONHARDT subsequently
passed a polygraph regarding the truthfulness of his affidavit. Polygraph examiner
Derry YORK concluded, It is my opinion that the physiological responses recorded
during the polygraph examination, in reference to the relevant questions, are
consistent with the usual indications of truthfulness.102
Based on Christy LEONHARDTs interview, KING prepared a Draft Affidavit103
which was emailed104 to LEONHARDT to review and amend as needed to ensure it
was an accurate reflection of the interview and her recollections. LEONHARDT
reviewed and signed her Affidavit in the presence of a notary.105
Debby KENNEDY originally agreed to complete an Affidavit, but to date has not.
Ted KULONGOSKI provided an unsigned type-written response.106 KULONGOSKI
subsequently provided a signed affidavit swearing to the accuracy of his previously
provided written response.107
Bernard GIUSTO was offered an Affidavit, as well as a polygraph examination and
he declined both. GIUSTO subsequently provided an affidavit swearing to the
accuracy of his responses to questions posed by DPSST investigators on October 1,
2007 and responses to questions posed by DOJ investigators on December 15, 2005.
The Assistant General Counsel in the Oregon State Bar investigation related to
LEONHARDTs assertions regarding KULONGOSKI commented that, Mr.
Leonhardt has acknowledged that he has no corroboration to support his
recollections. However, DPSST investigators have identified various witness who
cumulatively corroborated numerous portions of LEONHARDTs recollections
specifically related to GIUSTO.
A number of individuals interviewed assert that GIUSTO knew more about
GOLDSCHMIDTs crime than GIUSTO has admitted to the public. The allegation,
that the statements he made to the public in 2004 regarding his knowledge about
GOLDSCHMIDTs crime are in conflict with statements obtained during the
99
Ex A15l
Ex A15k
101
Ex A15m
102
Ex A30c
103
Ex A15l
104
Ex A29e
105
Ex A29g
106
Ex A63d
107
Ex A63g
100

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investigation, is conduct within DPSSTs jurisdiction. Therefore this allegation will
be referred to the Police Policy Committee to determine if GIUSTOs conduct
violated the established standards for Oregon public safety officers

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6)
Allegation 6: GIUSTO had improper contact with Margie GOLDSCHMIDT.

KIM asserted that GUISTOs personal relationship with Neil GOLDSCHMIDTs wife
Margie was improper.
The Investigative Team has determined that GIUSTO was assigned to the governors
security detail during the GOLDSCHMIDT administration. At that time Margie
GOLDSCHMIDT was married to Neil GOLDSCHMIDT. Margie GOLDSCHMIDT has
declined to comment on her relationship with GIUSTO, and DPSST does not have
jurisdiction over an individuals morality choices. Therefore, the portion of the allegation
relating to the marital status or relationship of either party will not be considered.
KIM provided no information to demonstrate that their relationship occurred while on
duty or that GIUSTO used state or agency resources to further the relationship.
Administrative closure; not in DPSSTs jurisdiction.

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7)
Allegation 7: GIUSTO had an inappropriate relationship with a female Gresham

City Councilwoman while he was the Chief of Gresham Police Department.
KIM asserted that he had heard that GIUSTO had engaged in a personal relationship with
a female city councilwoman while he was the Gresham Chief, and that this was
inappropriate. KIM had no first-hand knowledge, nor did he have the name of the city
councilwoman. KIM was unable to provide any information to support that GIUSTO had
personal gain because of this relationship.
When asked about the allegation of GIUSTO having a relationship with a Gresham City
Councilwoman during a portion of the time that GIUSTO was the Chief of Gresham
Police Department, GRAHAM identified Jaquenette MCINTIRE as a friend of
GIUSTOs, stating that he has no independent knowledge that they are more than just
friends.108 When interviewed, McINTIRE stated the allegation was false109; McINTIRE
acknowledged GIUSTO was only a friend of hers. MCINTIRE asserted that although she
and GIUSTO were friends, he did not ask for anything, or seek any benefit or advantage
that she would not have extended to another chief.
McINTIRE also questioned whether GIUSTO was the Chief during her tenure as
councilwoman, stating she served from 2002 to 2006. (GIUSTO served as Chief of
Gresham Police from August 1, 1996 to December 2, 2002) McINTIRE identified other
female councilwomen who may have served during GIUSTOs tenure.
Vicky THOMPSON was interviewed and confirmed that she had been a Gresham city
councilwoman when GIUSTO was the Chief of Police, from 1999 to the end of 2002.
When presented with the allegation that GIUSTO had obtained personal gain from his
friendship with a city councilwoman, THOMPSON stated that she and GIUSTO have
been friends for years, but I assure you he didnt get any special favors because hes a
friend of mine . . .I dont do things that way.110
Debra NOAH was interviewed and confirmed that she had been a Gresham City
councilwoman from January 1996 to January 2000. When advised that one of the
allegations against GIUSTO was that he received special treatment from a City
councilwoman with whom he had a special relationship, NOAH noted that there were
three women at the time and that she and GIUSTO were not friends outside of their
professional contacts, nor did GIUSTO ask for any special dispensation or courtesies.
111
Cathy Butts was contacted and responded via email on October 4, 2007, I was a
councilwoman in Gresham from 1999-2003 but I did not have a personal relationship
with Chief Giusto nor did the other councilwoman, Vicki Thompson, to my knowledge.
108
Ex A37a, p 35
Ex A33d, p
110
Ex A71c, p 2-3
111
Ex A70c, p 2-3
109

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As far as Chief Giusto asking for any special benefit or gain, the answer is no, never. . .
112
On October 1, 2007, GIUSTO was interviewed and was asked about his time as the Chief
of Police at Gresham Police Department and whether he knew Gresham city
councilwomen. GIUSTO stated he did and named several. GIUSTO stated that he spoke
with all of them. When asked if any of them and he had the type of relationship that he
felt he benefited from as the chief, GIUSTO stated no.113
(cross-reference page 217, THOMPSON Interview Summary)
(cross-reference page 217, NOAH Interview Summary)
(cross-reference page 124, BUTTS Email Summary)
(cross-reference page 217, McINTIRE Interview Summary)
(cross-reference page 148, GIUSTO Interview Summary)
Investigative Team Discussion: The investigative team considered this allegation to the
jurisdiction.
DPSST does not have jurisdiction over an individuals personal relationships. Therefore,
the portion of the allegation relating to the relationship of any party will not be
considered. KIM provided no information to demonstrate that this friendship had any
inappropriate results.
Investigative Team Finding:
112
113
Ex A69d
Ex A3d

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8)
Allegation 8: GIUSTO had inappropriate communications with a female

subordinate which resulted in threats to her.
KIM asserted that he received second-hand information that Jennifer OTT was the
subject of unwanted and inappropriate emails from GIUSTO, her superior. KIM further
asserted that once the unwanted emails came to GIUSTOs attention, an unknown person
threatened to fire OTT if she disclosed this information to anyone.
DPSST has determined that Jennifer OTT is the MCSO Human Resources Manager and
was not the subject of unwanted and inappropriate emails from GIUSTO.114
DPSST has determined that Deirdre McGILL, a civilian MCSO employee, was the
subject of what she perceived to be inappropriate contacts by GIUSTO. The contacts
included GIUSTO stopping by her office to engage in conversation; something that he
had not done prior to her assignment in the Hansen Building. Also cited was a call from
GIUSTO to MCGILLs personal cellular telephone while she was off duty, and receipt of
two bottles of wine from GIUSTO.115
MCGILL asserted that at no time did anyone threaten her employment, including any
MCSO staff members to whom she may have disclosed GIUSTOs contacts with her.
Conversely, MCGILL asserted that she told her co-workers that she would handle the
matter and asked for their cooperation. Contrary to MCGILLs request, Deputy Sean
CHRISTIAN interceded and reported to Chief Deputy GRAHAM116 and GIUSTO that
GIUSTOs contact with MCGILL was probably not a good idea.117,118 Shortly
thereafter, OTT visited MCGILL, expressed her concern for MCGILL, and inquired if
MCGILL wished to pursue a complaint against GIUSTO, to which MCGILL replied that
the matter had been handled.119 Both MCGILL and OTT deny any conversation about
MCGILLs employment being in jeopardy as a result of this event.120
(cross-reference page 217, OTT Interview Summary)
(cross-reference page 217, McGILL Interview Summary)
(cross-reference page 126, CHRISTIAN Interview Summary)
(cross-reference page 172, GRAHAM Interview Summary)
jurisdiction.
114
Ex A25b
Ex A43a
116
Ex A37a
117
Ex A42a
118
Ex A42a
119
Ex A26b
120
Ex A43a
115

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DPSST does not have jurisdiction over an individuals personal relationships. MCGILL
is not a complainant in this allegation and does not believe she was a victim of retaliatory
threats by GIUSTO or his staff.
Investigative Team Finding:
Administrative closure. Because there were several aspects to the allegation, there are
several findings:
The allegation that Jennifer OTT was the subject of unwanted emails from GIUSTO is
administratively closed; the allegation is false.
The allegation that a female was threatened with being fired is administratively closed;
the allegation is false.
The allegation that GIUSTO communicated with McGILL is administratively closed, the
allegation does not constitute misconduct for purposes of DPSST standards.

Investigation #2
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9)
Allegation 9: GIUSTO had an inappropriate relationship with a female volunteer

Chaplain, which affected the current male chaplains employment contract and
resulted in a loss of pay.
KIM asserted that GIUSTOs rumored relationship with a female volunteer chaplain
caused an employment contract change and pay reduction for the salaried Chaplain Ed
STELLE.
STELLE, the focus of KIMs allegation, does not perceive himself a victim of any
misconduct by GIUSTO, nor does he consider that TATEs presence had any negative
impact on him. 121 STELLE asserted that although there was a female chaplain that
GIUSTO asked him to mentor, her presence did not result in any negative impact on him.
Although STELLEs salary was affected by budgetary issues, he did not consider this a
negative matter, nor did he tie this occurrence to any impropriety by GIUSTO or his staff.
122
The investigative team identified Alice TATE as a female volunteer Chaplain who is also
friends with GIUSTO. When interviewed, TATE asserted that at no time did she receive
special treatment from GIUSTO as a result of her friendship. TATE pointed out that she
is a Chaplain to female inmates, whom STELLE does not counsel.123
(cross-reference page 217, STELLE Interview Summary)
(cross-reference page 217, TATE Interview Summary)
(cross-reference page 148, GIUSTO Interview Summary)
On October 1, 2007 when interviewed, GIUSTO stated that he moved STELLE over to
the law enforcement side where STELLEs focus has always been. GIUSTO also stated
that he cut STELLEs salary due to budget cuts. GIUSTO further explained that the
volunteer program was transferred to Catherine Moyer, MCSO staff assistant, for career
development. GIUSTO stated that it was STELLE who interviewed and hired TATE, but
GIUSTO who introduced the two.124
jurisdiction. STELLE does not see himself as a victim of any misconduct by GIUSTO or
as a result of any decision GIUSTO may have made which affected him. TATE asserts
that her friendship with GIUSTO has not resulted in personal gain or benefit.
121
Ex A34a
Ex A34a
123
Ex A38b
124
Ex A3
122

Investigation #2
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10)
Allegation 10: GIUSTO pursued a female PPB employee at a retirement dinner.
KIM asserted that GIUSTO had attended a PPB retirement function for the sole purpose
of making contact with a female PPB employee. The contact consisted of a conversation.
During his interview, KIM identified the retiree as Karl McDade and the female as
Angela OSWALT125. DPSST staff identified Karl McDADE, DPSST# 02994, as a
former Multnomah County Sheriffs Office deputy of fourteen (14) years and who then
served with Portland Police Bureau for twenty (20) years, retiring in 2005.
jurisdiction.
GIUSTO is entitled to speak to any individual he wishes at a social function. GIUSTOs
mere presence at a law enforcement retirement event does not constitute misconduct,
even if he was not invited.
Administrative closure; does not constitute misconduct.
125
Ex A1c, pg 49

Investigation #2
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11)
Allegation 11: GIUSTO inappropriately approved JEDDELOHs concealed

handgun license.
KIM asserted that GIUSTO improperly approved JEDDELOHs concealed handgun

license (CHL).
The DOJ investigation shows that Chief Deputy GRAHAM personally discussed
JEDDELOHs criminal background with GIUSTO, and that GIUSTO had access to
JEDDELOHs application file which contained the DUII diversion and the domestic
violence documentation.
Apparently MCSO staff believed GIUSTO had approved the license, based on GIUSTOs
affirmative handwritten notes and signatures in three separate locations, because a
telephone call was made to JEDDELOHs residence about the approved license.
When interviewed by DPSST investigators on July 17, 2007, GRAHAM asserted that he
not only met with GIUSTO and discussed JEDDELOHs criminal background, but
provided GIUSTO the entire application file with the materials that he had discussed with
GIUSTO. Additionally, GRAHAM asserted that it would have been significant to have
a subordinate tell the Sheriff that they were not going to approve a CHL and defer its
approval to the Sheriff.126
Based on the affirmative steps GIUSTO took in noting his approval in three separate
documents with the JEDDELOH application, it appears GIUSTO intended have the
license issued, until Lee (JEDDELOH) DOSS called him to complain about its issuance.
Administrative closure; although GIUSTO initially approved JEDDELOHs concealed
handgun license, ultimately the license was not issued. This does not constitute
misconduct for purpose of DPSST standards
126
Exhibit A37a

Investigation #2
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12)
Allegation 12: GIUSTOs statements to the public, in 2005 and 2007, and regarding
his knowledge of JEDDELOHs DUII diversion and domestic violence incident are
in conflict with statements made to DOJ investigators and physical evidence
obtained during the course of the investigation.
At issue in this allegation are what GIUSTO knew, when he knew it, and whether
GIUSTOs statements to the public accurately represented his knowledge.
The investigative team considered the public to include the citizens of Oregon, the
media and investigators.
On Thursday, January 4, 2007, the Oregon Department of Justice released their
report on GIUSTO, which covered his role in the JEDDELOH intervention as
well as the application by JEDDELOH for a concealed handgun license
(CHL).127
On January 5, 2007, Arthur Sulzberger of The Oregonian reported, Giusto
said Thursday that he had been unaware of allegations of domestic violence
when he signed the license. 128
On October 11, 2007, Nick BUDNICK of The Portland Tribune reported,
Giusto told reporters he had not been aware of Jeddelohs criminal
background, which included two arrests for drunken driving and allegations of
domestic violence, when he approved his application.129
On October 12, 2007, Les ZAITZ and Arthur SULZBERGER of The
Oregonian reported, In February 2005, Giusto approved Jeddelohs
application for the concealed handgun permit. He later said he had done so
before learning Jeddeloh had a drunken driving conviction, which would make
him ineligible under state law to get approval.130
On December 9, 2005, when DOJ investigators asked GIUSTO, Did you get
involved in that [approval of JEDDELOHs CHL] process at all? GIUSTO
replied, I did very late in the process and that was after Chief GRAHAM
brought it to my attention that before we approve it I should look carefully at,
127
A9a
Ex A12.32
129
Ex A12.115
130
Ex A12.116
128

Investigation #2
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uh, his file because there was an indication of domestic violence . . . .with that
I took a careful look at the file at that point.131
DOJ investigators later ask, so you learned of the DV reports, prior to talking
to . . Mrs. JEDDELOH? GIUSTO replied, I learned, no. I learned that
there was something in the file that I needed to report, some domestic violence.
. . I hadnt reviewed the reports yet, at that point.132 GIUSTO went on to
assert that he knew there was something that GRAHAM wanted him to look at
but. . . I hadnt specifically looked at them . . . when she [Lee JEDDELOH] .
. asked me to look at them . . . I went and got the file. In follow up, DOJ
investigators asked, you found out about the reports, or at least read the
reports after you talked to Mrs. JEDDELOH, to which GIUSTO replied,
Right. 133 (GIUSTO had already signed his approval on three separate
documents in the file, including one that specified both the DV and the DUII))
GIUSTO stated, I freely admit I didnt look at it carefully enough.134
Later GIUSTO stated, I recall Chief GRAHAM mentioning a DUI to me, too,
. . .in his original conversation.135
Relevant DOJ Investigative Interviews:
On November 15, 2005, DOJ investigators interviewed Jeanne BROWN, a
Senior Office Assistant with MCSO in the Concealed Handgun Section.
BROWN stated that after receiving JEDDELOHs completed application, she
conducted a standard background check that revealed JEDDELOH was
currently in diversion for DUII. BROWN also discovered a domestic violence
incident. MCSO conducted a number of criminal background checks on
February 4, 2005.136 A fax cover sheet from BROWN shows a request for
three (3) reports was sent to Portland Police Bureau Records on February 8,
2005.137 Brown received the three requested incident reports. 138
In a memorandum dated February 10, 2005, BROWN reported her findings to
GRAHAM.139 The memorandum is a single-paged document in which
BROWN details the Welfare Check, the Threats DV Report and the DUII
Diversion.
131
Ex A9d.16,p 3
Ex A9d.16, p 6
133
Ex A9d.16, p 6
134
Ex A9a, p. 32
135
Ex A9d.16, p 7
136
Ex A9g.5 - 16
137
Ex A9g. .18
138
Ex A9g. 19
139
Ex A9g.26
132

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Based on GIUSTOs approval on February 11, 2005, a CCW Applicant Card
was submitted February 18, 2005.140 Then, on February 22, 2005,
WALLIKER placed a sticky note in the file, Action suspended No Further
action until notified by Sheriff Giusto K. Walliker141
On November 8, 2005, DOJ investigators interviewed Brett ELLIOTT who
stated that Jeanne BROWN, a clerk for the concealed weapons section, told
him of JEDDELOHs DUII diversion and the domestic violence report.142
ELLIOTT provided DOJ investigators with a note that he believed was from
GIUSTO authorizing the permit to be issued. A sticky note indicated,
Chief, Go Ahead and Issue CHL The Sheriff 2/11/05 I have initialed the
(illegible).143 ELLIOTT recalled that, based on GIUSTOs approvals,
BROWN called and left a message for JEDDELOH at his home to pick up his
permit.144
On November 15, 2005, DOJ investigators interviewed Lee GRAHAM, then
MCSO Chief Deputy.145 GRAHAM told investigators that MCSO concealed
weapons staff provided him with information regarding JEDDELOHs DUII
diversion and the domestic violence report. Based on this, GRAHAM
forwarded the file and information to GIUSTO indicating it was his call.146
During a subsequent interview on November 18, 2005, GRAHAM told
investigators that when GIUSTO approved the application, GRAHAM gave
the file, with the approval, back to Kathy WALLIKER, the unit supervisor, to
issue the permit. GRAHAM stated that after GIUSTOs approval of the
application he did not have any conversations with GIUSTO regarding the
approval.147
On December 9, 2005, when DOJ investigators asked GIUSTO, Did you get
involved in that [approval of JEDDELOHs CHL] process at all? GIUSTO
replied, I did very late in the process and that was after Chief GRAHAM
brought it to my attention that before we approve it I should look carefully at,
un, his file because there was an indication of domestic violence . . . .with that
I took a careful look at the file at that point.148
DOJ investigators later ask, so you learned of the DV reports, prior to talking
to . . Mrs. JEDDELOH? GIUSTO replied, I learned, no. I learned that
there was something in the file that I needed to report, some domestic violence.
140
Ex A9g.27
Ex A9g.28
142
Ex A9f.1
143
Ex A9f, application with sticky note
144
Ex A9f, p 2
145
Ex A9d.12
146
Ex A9d.12, page 1
147
Ex A9d.12, page 2
148
Ex A9d.16,p 3
141

Investigation #2
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. . I hadnt reviewed the reports yet, at that point.149 GIUSTO went on to
assert that he knew there was something that GRAHAM wanted him to look at
but. . . I hadnt specifically looked at them . . . when she [Lee JEDDELOH] .
. asked me to look at them . . . I went and got the file. In follow up, DOJ
investigators asked, you found out about the reports, or at least read the
reports after you talked to Mrs. JEDDELOH, to which GIUSTO replied,
Right. 150 (GIUSTO had already signed his approval on three separate
documents in the file, one that specified both the DV and the DUII))
GIUSTO stated, I freely admit I didnt look at it carefully enough.151
Later GIUSTO stated, I recall Chief GRAHAM mentioning a DUI to me, too,
. . .in his original conversation.152
On August 18, 2006, DOJ investigators interviewed Kathleen WALLIKER,
Enforcement Support Manager and supervisor of the Concealed Handgun
License Unit. WALLIKER stated that BROWN approached her with the
JEDDELOH file and that BROWN explained she had issues with the
background check. WALLIKER stated that BROWN told her she was turning
the file over to GRAHAM to make the decision. 153
Relevant DPSST Investigation and Investigative Interviews:
On February 11, 2005, one day after GRAHAM told GIUSTO about
JEDDELOHs DUII and domestic violence incident, and provided GIUSTO
the CHL file:
1. GIUSTO wrote his approval on BROWNs memorandum that detailed
the Welfare Check, the Threats DV and the DUII diversion, signing it,
OK BAG 2/11/2005154
2. On a separate document GIUSTO provided a second approval, when he
wrote a note to GRAHAM on the Concealed Handgun License
Application, which appears to be on a sticky note and reads, Chief
Go Ahead and issue this CHL The Sheriff 02/11/2005 I have
initialed the file face sheet
3. On a third document GIUSTO provided a third approval, by writing
next to the Approved: location on the form, BG 2/11/2005
149
Ex A9d.16, p 6
Ex A9d.16, p 6
151
Ex A9a, p. 32
152
Ex A9d.16, p 7
153
Ex A9d.17
154
Ex A9g.26
150

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On July 17, 2007, DPSST investigators interviewed GRAHAM. GRAHAM
affirmed that he had received a February 10, 2005 memorandum155 from
BROWN related to her findings of JEDDELOHs criminal activity which
included a domestic violence incident.156GRAHAM stated, I wasnt going to
sign it, and I referred it to Sheriff Giusto to sign if he - - if he wished.157
GRAHAM described the chronology of the incident by stating that once
JEDDELOH came into the office and completed the application, several days
passed and he then received JEDDELOHs application file on his desk with a
memorandum from staff [BROWN] asking him to review the file. GRAHAM
stated that he reviewed the file and saw the domestic violence incident and did
not think the permit should be issued. GRAHAM stated he then took the
information to GIUSTO. GRAHAM stated he met with GIUSTO. GRAHAM
stated that he told GIUSTO that there were things in the file, specifically a
domestic violence allegation, and that he did not think JEDDELOH should be
issued a permit. GRAHAM specifically recalled telling GIUSTO that he
needed to review the file himself.158 GRAHAM told GIUSTO that he did not
think JEDDELOH should have a permit and that he [GRAHAM] was not
going to sign off on it.159 When asked if GIUSTO acknowledged he had heard
the information, GRAHAM recalled GIUSTO commenting something like,
Well, Ill review it later.160
GRAHAM then recalled seeking a sticky note on JEDDELOHs application
file with GIUSTOs signature saying, approved.161 GRAHAM stated he
recognized the handwriting as that of GIUSTO.162
When asked by investigators if GRAHAM had any further conversations about
the license application and GIUSTOs approval of it prior to the time it
became a hot topic, GRAHAM stated No . . .the timeline I remember is that
he approved it. They actually left a message for Mr. Jeddeloh to come in,
because he had to do some other parts of the process.163
GRAHAM recalled that GIUSTO mentioned to him that he was having phone
conversations with Mrs. JEDDELOH and that GIUSTO was having
reservations about issuing the permit, and eventually the permit was pulled and
not issued.164
155
Ex A9g. 26
Ex A37a, p 6
157
Ex A37a, p 7
158
Ex A37a, p 9
159
Ex A37a, p 11
160
Ex A37a, p 11
161
Ex A37a, p 12
162
Ex A37a, p 13
163
Ex A37a, p 14
164
Ex A37a, p 14
156

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In follow-up, investigators asked if GRAHAM had also told GIUSTO about
the DUII diversion and GRAHAM stated he believed he had. When asked
what impact the DUII would have had, GRAHAM stated it would have
normally excluded JEDDELOH from the process.165
Subsequent to GRAHAMs interview, he signed an Affidavit attesting to his
interaction with GIUSTO.166 (cross-reference page 172, GRAHAM Interview
Summary)
On October 1, 2007, DPSST investigators interviewed GIUSTO about
JEDDELOHs application. GIUSTO stated, the file comes up to me . .and I
look at it briefly. GIUSTO then stated he signed the document to give
[JEDDELOH] the permit and the file went back to GRAHAM. GIUSTO then
stated GRAHAM came back to him and asked if GIUSTO had looked at the
application carefully because GRAHAM was not comfortable issuing the
permit. GIUSTO confirmed that GRAHAM pointed out both the DUII
diversion and the domestic violence. 167
GIUSTO asserted that during the time between when he had approved the
permit and when GRAHAM returned to him, asking that GIUSTO look at the
application again, MCSO staff called the JEDDELOH residence.168
Investigators asked GIUSTO if he recalled GRAHAM coming to him prior to
anyone approving the file and telling GIUSTO that there was a DV problem
and that he would not approve the permit and that if GIUSTO wanted to
approve it, it would be up to GIUSTO. GIUSTO responded, I dont
remember that order at all . . .Im not saying it couldnt have been thats not
the way I remember it . . .169
When asked how many concealed handgun license applications had come back
to GIUSTO for his signature, GIUSTO stated, I think that . . . might have
been the only one.170 When asked if it would then have set off a red flag
when the application came to him for signature, GIUSTO stated, No . . the
staff gets little things backwards like . . .theres something special about me
signing this particular thing because Id asked for somebody to deliver the
application . . .
Investigators asked whether GIUSTO had given staff similar instructions to
provide a permit to other individuals; GIUSTO responded, Yeah. I have.
When asked if in those cases, the staff had brought the application back to him,
165
Ex A37a, p 15
Ex A37d
167
Ex A3d,p 71
168
Ex A3d, p 74
169
Ex A3d, p 75
170
Ex A3d, p 77
166

Investigation #2
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1/16/2008

GIUSTO stated, Well, I dont think quite in the same way because this didnt
go from me to the chief deputy to the staff people.171
GIUSTO was asked if it would be incorrect if GRAHAM were to have told
investigators that when he reviewed JEDDELOHs file and saw the DUII and
the DV, that he came to GIUSTO and gave GIUSTO a verbal rundown of the
criminal history and then asked GIUSTO to review the criminal history.
GIUSTO stated, . . that part would be incorrect in terms of detail. In terms of
the intent of what he [GRAHAM] did, he said, You might want to take a look
at this. When asked if GRAHAM ever told GIUSTO there was a DUII
diversion and a DV, GIUSTO stated, no . . .I think he said there was a DUI
diversion . . .172
When asked if GIUSTO recalled GRAHAM telling him, Im not going to sign
this. If you want it done, youre going to have to sign it yourself, GIUSTO
stated, I dont remember it in those terms, but he could have . . he could
have.173 (cross-reference page 148, GIUSTO Interview Summary)
Investigative Team analysis:
GIUSTOs public statements that he was unaware and did not notice the domestic violence
incident in JEDDELOHs file conflicts with statements and physical evidence obtained in
the course of the investigation:
1. GIUSTO acknowledged to DOJ his awareness of a domestic violence incident
prior to his approval of the license.174
2. GIUSTO public statement to the media that he was unaware of allegations of
domestic violence is in conflict with what he told DOJ investigators and with
his signature on the memorandum.
3. GIUSTOs statement is also in conflict with GRAHAMs assertion that he told
GIUSTO of both the DUII and the domestic violence, and provided GIUSTO
with the application file, prior to GUISTOs written approval.
4. GIUSTOs statement that he got involved in the process very late is in conflict
with the date of his signatures of approval in JEDDELOHs CHL file one day
after being told of JEDDELOHs DUII and the domestic violence incident.
Clearly GIUSTO got involved early in the process; within approximately 24
hours from being advised of JEDDELOHs criminal history, on February 11,
2005, and only late in the process, on February 22, 2005, when he provided
written confirmation of the termination of the process, to address his earlier
approval of the CHL.
171
Ex A3d, p 79
Ex A3d, p 80
173
Ex A3d, p 81
174
Ex A3d, p 3
172

Investigation #2
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1/16/2008

The investigative team also learned:
1. In general it was not GIUSTOs role to sign CHL.
2. GIUSTO had never signed a CHL up to this point.
3. GRAHAM said he physically brought the application to GIUSTO. This was an
event that was not routine and would appear to be significant.
4. GRAHAM told GIUSTO he would not approve the permit and that GIUSTO
would have to. This was also an event that was not routine and would appear to
be significant.
5. GIUSTO gave his written approval in three (3) separate locations:
a. On a sticky note to GRAHAM, dated 02 11 05
b. On the License application, dated 02 11 05
c. On the 1-page memorandum identifying the DUII diversion and the
domestic violence, dated 02 11 05
Statements from witnesses, and written approvals from GIUSTO of JEDDELOHs
CHL permit, conflict with GIUSTOs statement to the public that he did not know
about the DUI and DV until after he was contacted by Mrs. JEDDELOH. This
allegation is conduct within DPSSTs jurisdiction. Therefore, this allegation will be
referred to the Police Policy Committee to determine if GIUSTOs conduct violated
the established standards for Oregon public safety officers.

Investigation #2
Page 74 of 302
1/16/2008
13)
Allegation 13 GIUSTO altered, or had altered, JEDDELOHs concealed handgun

license application and file
In his letter KIM asserted that GIUSTO directed his MCSO executive staff to cover up
his actions by altering the file prior to it being sent to DOJ.
When interviewed, KIM asserted at one point that they altered . . . fabricated a whole
new document and there were different writings on it. KIM later asserted that the
whole file disappeared. KIM also asserted that the file disappeared and then
reappeared with different information.
According to the DOJ investigation, ELLIOTT provided DOJ a copy of the JEDDELOH
application with a sticky note on it in which GIUSTO approved the CHL. Later when
a copy of the application was sent to DOJ along with other documents, the sticky note
was not present.
Also, according to the DOJ investigation, BROWN asserted that the JEDDELOH
application file was on her desk and for a period of time it was removed. The file was
returned at a later date.
Investigative Team Discussion: There is no indication that any other discrepancies
were found of the CHL application by DOJ. Additionally, there is no evidence that
GIUSTO removed, or had removed, the sticky note approving the CHL.
Administrative closure; the allegation is false

Investigation #2
Page 75 of 302
1/16/2008
14)
Allegation 14: GIUSTO misused the protective order that Lee (JEDDELOH) DOSS
obtained by threatening Jim JEDDELOH.
KIM asserted that GUISTOs use of the protective order to threaten JEDDELOH
constituted manipulation and misuse of the order.
It appears that GUISTO sought and received counsel from District Attorney SHRUNK
regarding JEDDELOHs prior domestic violence-related event and the pending
intervention along with the protective order that was issued. There is conflicting
information on whether or to what degree GIUSTOs position played a role in the other
participants decisions to also become involved in the intervention.
According to the DOJ investigation, There is some evidence that GIUSTO developed an
intimate relationship with Lee JEDDELOH after the intervention. . . There is some
evidence that GIUSTO used the threat of service of a restraining order as a tool to force
Jim Jeddeloh to attend the Betty Ford Clinic. The restraining order had been lawfully
issued by a court. Giusto was authorized by law to cause its service. Under the
circumstances, Giustos threat to do something he had a legal right to do cannot be said to
constitute an unauthorized exercise of official duties. And ultimately, the restraining
order was served.175
In his interview ELLIOTT asserted that it was his experience that when a judge signs an
Order, it is the judges expectation that it is for someones protection and therefore they
have an obligation to serve it; it would be unusual if it were not served.176
Investigative Team Discussion: The DOJ investigation found that GIUSTO did use the
Order as leverage and GIUSTO admits to this. DOJ found that GIUSTOs threat to do
something he had a legal right to do cannot be said to constitute an unauthorized exercise
of official duties. DPSST concludes that GIUSTO acted within the scope of the law.
As an elected official responsible for administering his own agency, GIUSTO has the
authority to set and modify policy, and has broad discretion in defining and exercising
his duties, (Ref ORS 206.010 206.345) (emphasis added) . .
Administratively closed; the conduct does not constitute misconduct for purposes of
DPSSTs jurisdiction.
175
176
Ex A9a
Ex 64a

Investigation #2
Page 76 of 302
1/16/2008
15)
Allegation 15: GIUSTO engaged in a personal relationship with Lee (JEDDELOH)

DOSS arising from GIUSTOs efforts to conceal his previous bad act, i.e., the
issuance of a Concealed Handgun License.
KIM asserted that in an effort to conceal his previous bad act in [Lees] eyes, GIUSTO
developed a personal relationship with her.
Investigative Team Discussion: The motive of a certified officer to seek a relationship
with another person is not under DPSSTs jurisdiction.
Administrative closure; does not constitute misconduct for purposes of DPSST
standards.

Investigation #2
Page 77 of 302
1/16/2008
16)
Allegation 16: GIUSTO violated agency policy by sending numerous emails to Lee
DOSS from his work computer.
KIM asserted that GIUSTO violated his own agency policy when he sent and or received
personal emails to or from Lee DOSS. KIM had no specific information on this
allegation.
Investigative Team Discussion: MCSO Policy 4.07 prohibits employees from

conducting personal business while on duty; lunch periods and breaks are excepted.
GIUSTO is not an employee of MCSO, he is an elected official. As an elected official,
GIUSTO is not bound by the working hour or work day constraints of an employee,
therefore there is no way to determine whether GIUSTO was working or not working
when he sent or received emails from DOSS.
MCSO Policy 18.07 prohibits inappropriate communications and activities not
consistent with the mission or objectives of MCSO. As an elected official responsible
for administering his own agency, GIUSTO has the authority to set and modify policy,
and has broad discretion in defining and exercising his duties, (Ref ORS 206.010
206.345) (emphasis added)
Administrative closure; does not constitute misconduct for purpose of DPSST
standards.

Investigation #2
Page 78 of 302
1/16/2008
17)
Allegation 17: GIUISTOs statements to the public in 2005, and in a 2006

deposition regarding a trip to Seattle with Lee DOSS while her husband was in
rehabilitation, are in conflict with statements he made to DPSST.
Initially DPSST considered three parts to this allegation. Having received input from
Giusto, DPSST concurs that Part B and Part C may be administratively closed. Part A
remains and is forwarded to the Policy Committee for consideration. See Investigative
Team Findings for analysis.
Part A: GIUSTO was untruthful with the media, and in a deposition for divorce
proceedings between James and Lee JEDDELOH, regarding a trip he took to Seattle with
Mrs. JEDDELOH while her husband was in rehabilitation.
Part B: GIUSTO was untruthful with the media when he stated he had not offered Lee
JEDDELOH $10,000 to pay for her husbands rehabilitation.
Part C: GIUSTO was untruthful with the media when he stated he had not been involved
in the planning of the intervention until the night before or maybe two days before.
An individuals personal relationships, in general, are a private matter. In this
allegation, the focus centers on what GIUSTO chose to tell the public about his
relationship with DOSS, and whether GIUSTOs statements to the public were
truthful.
The investigative team considers the public to include the citizens of Oregon, the
media and investigators.
Initially at issue was whether GIUSTOs statements to the public regarding his
relationship with DOSS were truthful.
As the fact-finding investigation proceeded, the investigative teams concern
expanded to include whether GIUSTO had been untruthful with DOJ investigators in
their criminal investigation.
The investigative team was not concerned with the nature of the relationship between
GIUSTO and DOSS, but focused solely on GIUSTOs public statements and
whether they were truthful regarding:
1. A trip to Seattle
2. A loan offer of $10,000
3. When GIUSTOs involvement in the intervention began

Investigation #2
Page 79 of 302
1/16/2008

On October 12, 2007, Les ZAITZ and Arthur SULZBERGER of The
Oregonian reported, Investigators in the current review asked her [Lee
DOSS] about a trip to Seattle. She told The Oregonian that soon after her
husband left for rehabilitation, she asked Giusto to drive her to Seattle to see
her college-age daughter. She said it was not a romantic trip and that the two
stayed at her daughters apartment with her boyfriend. In a July 23, 2005,
interview with The Oregonian, Giusto was asked about traveling to Seattle
with Doss in May 2005. I didnt take a trip to Seattle, he said.177
GIUSTO gave a deposition in Clackamas County on October 6th, 2006 for Lee
Jeddeloh in her petition for divorce from James Jeddeloh. Below are pertinent
excerpts:
Q: Have you traveled outside the state of Oregon with Ms. Jeddeloh in the
years 2004, 2005, 2006 to date?
A:
Yes
Q:
. . . where did you travel?
A:
...
To Virginia and Washington DC. . .
Q: . . . any other trips outside the state of Oregon in 2004, 2005 and 2006
with Ms. Jeddeloh?
A:
No
....
Q: And you cant recall any other instances of travel with Ms. Jeddeloh
outside the state of Oregon in 2004, 2005, 2006?
A:
No . . .
...
Q: Who is Ashby Collinson?
177
A:
Lees daughter.
Q:
In the last 30 days have you traveled to Seattle with Ms. Collinson?
Ex A12.116

Investigation #2
Page 80 of 302
1/16/2008
A:
Yes.
Q:
Was Ms. Jeddeloh with you?
A:
Yes.
Q:
So thats another instance of travel outside the state.
A:
Oh, sorry, Okay.
...
Q: Having refreshed your recollection on that trip, are you aware of any
other travel with Ms. Jeddeloh outside the geographical boundary of the state
of Oregon in 2004, 2005, 2006?
A:
I just cant recall.
Relevant statements to DOJ:

On December 9, 2005, DOJ investigators asked GIUSTO when he first met
Lee (JEDDELOH) DOSS and he stated he does not recall when he first met
her. GIUSTO believes his first conversation with her was in January [2005].178
GIUSTO then described a phone conversation [in February] in which DOSS
called him after hearing a telephone message left by MCSO Concealed
Handgun License Unit personnel.179 GIUSTO stated he put a stop to the CHL
on February 22nd.180 GIUSTO related his ongoing conversations181 with Lee
JEDDELOH and cited an April 15th late phone call from Lee DOSS
complaining about Jim JEDDELOHs drinking.182 GIUSTO described the
intervention [May 6, 2005] and his role.
When asked if GIUSTO became involved in the planning of the intervention,
he stated, I did not, except for the pre-planning the night before.183 GIUSTO
then stated he spoke with Dr. SAVAGE, either the day before or maybe two
days before184 When the investigators asked GIUSTO whether, if they were
to obtain the emails between himself and Lee JEDDELOH, there would be
anything that would not agree with what GIUSTO had told investigators
during the interview, GIUSTO stated, I dont think so.. . .Im not clear if there
178
Ex A9d.16, p 2
Ex A9d. 16, p 4
180
Ex A9d.16, p 6
181
Ex A9d.16, p 10 March
182
Ex A9d.16, p 9
183
Ex A9d.16, p 10
184
Ex A9d.16, p 10
179

Investigation #2
Page 81 of 302
1/16/2008

were any emails, um . . .Im just tempted to say I dont recall . . . I dont recall
emails.185
On December 27, 2005, GIUSTO wrote a letter to the Oregon Department of
Justice. Within his letter GIUSTO stated, In this email Mrs. Jeddeloh tells
Mr. Geckler that I would loan her $10,000 to help pay for the intervention.
While Mrs. JEDDELOH hay have understood my offer to help the Jeddeloh
family in this intervention as including personal financial assistance, I did not
offer to loan nor did I loan or give Mrs. Jeddeloh any money for the
intervention. As shown below, the costs of the intervention were picked up
largely by Mr. Jeddelohs firm and/or partners. I contributed no money toward
the intervention.186
Relevant Emails:
DOJ investigators obtained emails which contained the following
chronological communications:
On April 28, 2005, an email from Lee JEDDELOH to her attorney regarding
the intervention. GIUSTO is ccd.
Sheriff Guisto [sic] is in daily contact with us . . .187
On May 3, 2005, an email from Lee JEDDELOH to GECKLER (intervention
worker) regarding the intervention. GIUSTO is ccd.
Sheriff Bernie Giusto, our friend, is loaning me the $10,000 to have
available to pay you . . .the Sheriff has a good point, that selling my
wedding ring to pay to, will send a discouraging msg to JJ. I should
have it on when I pick JJ up at airport Wed. night. . . would you please
phone Sheriff Guisto [sic] at 503-730-0621, where you can leave a
voicemail, to make the financial arrangements that you require? I will
pay him back right away . . . ,188
On May 4, 2005, an email from Lee JEDDELOH to KALBERG (Jim
JEDDELOHs partner in firm and a participant in the intervention) regarding
the intervention. GIUSTO is ccd.
Hi Tim . . .Heard from the Sheriff about your conversation . . .189
185
Ex A9d.16, p 33
Ex A9i.2
187
Ex A9h.4
188
Ex A9h.5
189
Ex A9h. 6
186

Investigation #2
Page 82 of 302
1/16/2008

On May 5, 2005, email from Lee JEDDELOH to WIEDEN regarding the
intervention. GIUSTO is ccd.
. . Sheriff Bernie Giusto is available for you to contact about any of
this. His direct line: 503-730-0621. He and the others will be at the
downtown Hilton conference room . . .at 6 pm this evening.190
On May 5, 2005, email from Lee JEDDELOH to
SHERIFF".
I intend to be at courthouse by 11 this morning.191
On May 5, 2005, email from Ashby (Lee JEDDELOHs daughter) to GIUSTO
and Lee JEDDELOH.
Hi Mom and Bernie . . .Bernie: Thanks for your help. It means a lot to
me that my Mom and sisters are being taken care of 192
On June 22, 2005, email from GIUSTO to ashby,
As for your mom, I am amazed that she has allowed me [in] her life . .
she has earned my admiration. 193
Relevant Telephone Analysis:
PARSONS conducted a telephone analysis of the telephone records produced
by Jim JEDDELOH, through his attorney.
PARSONS determined that in the eleven days prior to the intervention, Lee
JEDDELOH made sixty-four (64) telephone calls to GIUSTOs home or cell
phone.194
Relevant statements to DPSST:
On October 1, 2007, DPSST investigators interviewed GIUSTO and when
asked, While he [Jim JEDDELOH] was in rehab, did you and Lee go to
Seattle for a weekend together . . .? GIUSTO replied, Yes. When asked
were her children with her at the time? GIUSTO replied, No. When
asked, so it was just the two of you on that particular trip? GIUSTO replied,
Right.195 When asked, Do you recall which hotel you stayed at in Seattle?
190
Ex A9h. 7
Ex A9h.8
192
Ex A9h.9
193
Ex A9i.11
194
Ex A73a, 73b
195
Ex A3d, p 97, lines 5-24
191

Investigation #2
Page 83 of 302
1/16/2008

GIUSTO stated, I dont. When asked, Downtown or airport? GIUSTO
stated, Downtown.
Investigative Team Analysis and Findings:
Part A:
Item 1: GIUSTO made a statement to the media that he had not taken a trip to Seattle
with Lee JEDDELOH while Jim JEDDELOH was in rehabilitation.
Item 2: In a deposition, when asked if GIUSTO had traveled outside the state of
Oregon with Ms. JEDDELOH, GIUSTO first omitted his trip to Seattle when he
described his travel. Then, on two subsequent occasions, when asked if he could recall
any other instances of traveling outside the state of Oregon with Ms. JEDDELOH,
GIUSTO stated, No. It was only after being asked if GIUSTO traveled with Ms.
JEDDELOHs daughter to Seattle, did GIUSTO then admit Ms. JEDDELOH was with
him. Subsequent to that, when asked if he had taken any other trips, GIUSTO stated, I
dont recall.
These statements are in conflict with GIUSTOs statement to DPSST investigators that he
did take a trip to Seattle with Lee JEDDELOH while her husband was in rehabilitation.
The allegation that he was untruthful about his trip to Seattle with Mrs. JEDDELOH is
conduct within DPSSTs jurisdiction. Therefore, this allegation will be referred to the
Police Policy Committee to determine if GIUSTOs conduct violated the established
standards for Oregon public safety officers.
Part B:
GIUSTO asserts that he did not offer to loan Lee DOSS $10,000, contrary to an email
that DOSS sent to a third party indicating that he made the offer. Although the DOJ
investigation reviewed this issue in their criminal case and under a different burden of
proof standard, DPSST considered the issue related to its administrative jurisdiction.
Documents received subsequent to the draft report are consistent with GIUSTOs
position. Staff concurs with GIUSTOs response; this portion of the case will be
administratively closed.
Part C:
GIUSTO asserts that because DPSST does not define involvement, this portion of the
case is a vague and ambiguous allegation. At issue was GIUSTOs involvement in an
intervention which subsequently lead to Jim JEDDELOH going to rehabilitation and
GIUSTO and Jim JEDDELOHs wife, Lee DOSS, going to Seattle for a weekend.
Involvement is subject to different interpretations. Staff concurs with GIUSTOs
response; this portion of the case will be administratively closed.

Investigation #2
Page 84 of 302
1/16/2008
18)
Allegation 18: GIUSTO has lost public confidence as the result of the prior
allegations, and that the Board of Multnomah County Commissioners made an
inquiry whether criminal conduct was involved but failed to determine if moral
fitness issues would disqualify GIUSTO.
Investigative Team Discussion: KIM asserted that GIUSTO lost public confidence. As
an elected official, if the public has lost confidence in him as a leader, or his leadership
abilities, their recourse is a recall.
KIM has also asserted that the Board of Multnomah County Commissioners made an
inquiry whether there was criminal conduct involved but failed to determine if moral
fitness issues would disqualify GIUSTO. DPSST has no jurisdiction over what the Board
of Multnomah County Commissioners uses as criteria to evaluate an elected official.
Administrative closure, not within DPSSTs jurisdiction

Investigation #2
Page 85 of 302
1/16/2008
19)
Allegation 19: KIM asserted the Oregon Department of Justice investigation against
GIUSTO was tainted in the publics eye as a result of political connections
between GIUSTO and KULONGOSKI.
KIM alleged that because of a political party connection between GIUSTO and
KULONGOSKI, the DOJ investigation was tainted. KIM could provide no proof or
evidence of this other than second-hand conjecture.
When investigators interviewed KIM, investigators explained to KIM that his allegation
that the Attorney Generals office being somehow influenced by the Democratic Party
and the governor was not in DPSSTs jurisdiction KIM suggested, Well throw that one
out.196
Investigative Team Discussion: In reviewing the DOJ investigation, it appears their
focus remained on whether GIUSTOs actions were criminal. There is no indication of
any connection to KULONGOSKI in this investigation.
Investigative Team Findings
Administrative closure; not within DPSSTs jurisdiction
196
Ex A1c, p 90

Investigation #2
Page 86 of 302
1/16/2008
20)
Allegation 20: GIUSTO improperly appeared in uniform to campaign for

KULONGOSKI.
KIM was unable to provide any specifics regarding the rebuke that GIUSTO received
from IACP. Furthermore, if this rebuke was public knowledge, the public had an
opportunity to take this into account during the subsequent election process.
Investigative Team Discussion: GIUSTO is one of many who have appeared in uniform
on behalf of various political positions or candidates. Additionally, while there may be
policy against this conduct, DPSST concludes that this allegation is beyond our
jurisdiction and that GIUSTO enjoys the First Amendment protections afforded to him
regarding free speech.
Administrative closure; does not constitute misconduct for purposes of DPSST standards.

Investigation #2
Page 87 of 302
1/16/2008
21)
Allegation 21: GIUSTO has demonstrated poor management as shown by the

Investigative Report conducted by the Multnomah County District Attorneys
Office.
Investigative Team Discussion: KIM alleges that since the Multnomah County
Investigative Report identified areas of concern, DPSST should consider that Report. In
the investigative teams review of the mentioned document the focus appears to be on
management and leadership issues; these are not within DPSSTs jurisdiction.
Furthermore, GIUSTO is an elected official; therefore, if the public has lost confidence in
him as a leader, their recourse is a recall.
Administrative closure, not within DPSSTs jurisdiction

Investigation #2
Page 88 of 302
1/16/2008
22)
Allegation 22: GIUSTO has failed to maintain a high ethical standard, and therefore
his subordinates have engaged in similar conduct that has led to some subordinate
officers arrests.
Investigative Team Discussion: DPSST recognizes that subordinates of an organization

often mirror their leadership in conduct and attitude. At present there is nothing beyond
speculation that individual subordinates conduct is tied to what may or may not be
perceived as acceptable standards based on GIUSTOs conduct.
Investigative Team Findings
Administrative closure; there is no way to prove or disprove the allegation.

Investigation #2
Page 89 of 302
1/16/2008
23)
Allegation 23: GIUSTO has been publicly humiliated through the media.
Investigative Team Discussion: GIUSTO is an elected official; therefore if the public has
lost confidence in him as a leader, their recourse is a recall. Furthermore, GIUSTO, like
any public figure, is subject to media coverage.

Investigation #2
Page 90 of 302
1/16/2008
24)
Allegation 24: GIUSTO improperly directed his staff to check Complainant Robert
KIM in LEDS.
GIUSTO directed Todd SHANKS to look up Robert KIM in LEDS. In his letter dated
May 7, 2007, GIUSTO asserted that the basis for the Law Enforcement Data Systems
(LEDS) check was to determine if KIM posed a threat to the Sheriff and agency
members.197 Subsequent to this explanation DPSST sent an inquiry to LEDS to
determine if LEDS had concerns about the inquiry.198 LEDS Auditor Dan MALIN
responded in a letter dated July 2, 2007 in which he stated, . . . I did not find the LEDS
system was used inappropriately in this instance.199
In Auditor MALINs response to DPSST, MALIN questioned DPSSTs investigative
staffs use of the LEDS to run a similar check on KIM. In responding to this inquiry,
Director MINNIS provided a letter of explanation.200 On July 16, 2007, MALIN sent a
letter to MINNIS in which he stated, I appreciate Ms. KINGs description and
explanation of events and agree that these inquiries constitute appropriate use of
LEDS.201
Investigative Team Discussion: GIUSTO properly used LEDS.
197
Ex A3b
Ex A5a
199
Ex A5c
200
Ex Ah
201
Ex Ai
198

Investigation #2
Page 91 of 302
1/16/2008

G. INVESTIGATIVE ACTIONS TAKEN
The following entries denote the chronological investigation:
April 24, 2007
MINNIS/LORANCE/KING - Robert KIM complaint received202
MINNIS/KING/LORANCE - Identification of investigative team
April 30, 2007
KING - Employee Profile on GIUSTO203
KING - DMV address verification and verification of DOB for OJIN checks completed
on Robert KIM204
May 1, 2007
MINNIS/LORANCE/KING- Receipt of Letter from GIUSTO dated May 1, 2007205
KING Reviewed OAR 259-008-0010206, OAR 259 008 0070207 ORS 206.010 et. al. 208,
ORS 166.291209
KING Reviewed news clippings 210
May 4, 2007
KING Developed Investigative Plan211
KING Developed Initial Fact Finding
KING Developed Investigation Overview flow chart (ref. 1)
KING Developed Agenda212
May 7, 2007
KING - Receipt of letter from MCCAIN dated May 7, 2007213
KING Receipt of complaint of Don DRIGGS214
ANGLEMIER Review investigative packet
202
Ex A1a
Ex A7
204
Ex A1b
205
Ex A3a
206
Ex A10
207
Ex A11
208
Ex A13a
209
Ex A13b
210
Ex A12
211
Ex A2a
212
Ex A2b
213
Ex A3b
214
Ex A8
203

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May 9, 2007
KING/LORANCE/GABLIKS/MADDUX/ANGLEMIER/PARSONS - Initial
Investigative team meeting
KING - Received from MADDUX a copy of DOJ Investigative Report on GIUSTO
regarding criminal investigation regarding the issuance of a concealed handgun license to
Jim JEDDELOH 215
KING Letter to MADDUX, requesting additional documents216
ANGLEMIER Case review
May 10, 2007
KING Email to Investigative Team Information requested217
May 11, 2007
TWEEDT Sent KING underlying investigative materials from DOJ investigation.218
May 17, 2007
KING - Email to Investigative Team DOJ Investigation219
TWEEDT Case Review
May 18, 2007
TWEEDT Case Review
May 22, 2007
PARSONS/KING Interview of KIM220
KING Email Investigative Team Update 221
MINNIS/LORANCE/KING - Email from Commissioner Lisa NAITO, re PAUGH
Complaint222
June 11, 2007
KING/LORANCE/MINNIS Received complaint of Fred LEONHARDT.223
June 12, 2007
PARSONS/KING - Interview of Lisa NAITO#1224
KING Email Investigative Team Update225
KING KIM Transcript review
PARSONS Called LEONHARDT, set interview date of 06 13 07
215
Ex A9a
Ex A9b
217
Ex A2c
218
Ex A9c - d
219
Ex A2d
220
Ex A1c
221
Ex A2e
222
Ex A61a-b
223
Ex A15a
224
Ex A16c
225
Ex A2f
216

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TWEEDT Case Review
June 15, 2007

TWEEDT Case Review
June 19, 2007
PARSONS/KING Interview of Fred LEONHARDT226
June 20, 2007
TWEEDT Case Review
June 21, 2007
KING Internet search of Tom GIUSTO228
PARSONS Handwritten note on initial contact229
PARSONS/KING - Interview of Tom GIUSTO230
PARSONS email to KING, ref. Tom GIUSTO conversation231
June 22, 2007
TWEEDT Case Review
June 25, 2007
TWEEDT Case Review
June 26, 2007
MINNIS/LORANCE/KING Receipt of anonymous complaint regarding potential
witnesses, BICART and YOUMANS232
KING - Contact information on Helen BICART,
KING - Email to DOJ Watch Center for contact information on Neil and Diane
GOLDSCHMIDT, Margie GOLDSCHMIDT234, Debby (Kennedy) STONE, Gregg
KANTOR235, Thomas IMESON236
PARSONS/KING - Interview of Helen BICART237
226
Ex A15f
Ex A2g
228
Ex A17a
229
Ex A17b
230
Ex A17c
231
Ex A17d
232
Ex A18a
233
Ex A22a
234
Ex A21a
235
Ex A23b
236
Ex A24b
237
Ex A18b
227

Investigation #2
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June 27, 2007
KING Review of LEONHARDT transcript
KING Email to/from DOJ Watch Center for Neil GOLDSCHMIDT contact info
KING Review of news clippings
June 28, 2007
KING - Email to MCCAIN for Information on Jennifer OTT239
KING - Email to MCCAIN on Organizational charts and Standard Operating Procedures
KING - Research on Multnomah County District Attorneys 2006 Independent Review
KING - Email to MCCAIN on Response to MCDA Independent Review
KING Telephone conversation with MCCAIN, limited anonymity for KIM sources240
KING Email to/from OCONNELL, LEDS, on GIUSTOs LEDS check241
KING Email to ANGLEMIER statutory rape, statute of limitations research242
TWEEDT Case Review
June 29, 2007
KING - Email to/from DOJ Watch Center for contact information on Deborah H.
YOUMANS243
KING - Case Prep Flow charts of relationship and timeline
KING Review of transcripts of Tom GIUSTO, BICART and MCCAIN interviews
KING Review of Multnomah County DA Independent Review and GIUSTOs
response
KING Draft Investigative Team Agenda preparation245
KING Email to LEDS on GIUSTOs direction for SHANKS to run KIM on LEDS
KING Preparation of Exhibit List
KING Email Investigative Team Agenda
TWEEDT Case Review
KING Email to/from LEONHARDT246
July 2, 2007
KING - Email to MCCAIN on Special Investigations Unit and personnel
KING - Phone conversation with DRIGGS, advised his case is a separate matter, and
closed issue as unrelated to this investigation
KING Review MALIN (LEDS) response to LEDS inquiry247
238
Ex A2h
Ex A25a
240
Ex A26a
241
Ex A5a,5b
242
Ex A6a
243
Ex A19a-c
244
Ex A2i
245
Ex A2j
246
Ex A15g
247
Ex A5c-e
239

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July 3, 2007
KING/TWEEDT - on JEDDELOH license documents, et al248
KING research ORS 206.010 - .345
KING - Email to LEONHARDT with follow up questions249
KING Preparation of LEONHARDT Affidavit250
KING Preparation of LEDS inquiry to MINNIS response through LORANCE251
Email to/from KING/DOJ Watch Center locate on Debby KENNEDY252
July 5, 2007
KING Preparation of Timeline and Relationships flow chart development
KING Preparation of Interview Questions
July 6, 2007
ANGLEMIER Research statutory rape, statute of limitations
July 9, 2007
KING Email to/from SIMMONS polygraph examiner research
July 10, 2007
KING - Email to DOJ Watch Center for contact information on witnesses
KING - Email to/from MCCAIN on contact info for witnesses
KING Review LEONHARDTs signed Affidavit254
KING Memo to file, conversation with Derry YORK, polygraph examiner, provided
LEONHARDTs affidavit.
KING Investigative Team Agenda preparation256
TWEEDT Case Review
July 11, 2007
LORANCE/KING/TWEEDT/PARSONS/ANGLEMIER - Investigative Team Meeting257
KING - Email from DOJ Watch Center on contact info for witnesses
ANGLEMIER Case Review
TWEEDT Case Review
248
Ex A9e - g
Ex A15h I, j
250
Ex A15k-l
251
Ex A5f - g
252
Ex A20a - b
253
Ex A2l
254
Ex A15m
255
Ex A2m
256
Ex A2d
257
Ex A2n
249

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July 12, 2007
LORANCE Email to KING Investigative Team consensus on consistent interview
process258
MINNIS Letter to MALIN, response to inquiry re: LEDS use259
PARSONS Telephone interview of NAITO260
July 16, 2007
KING - Telephone message for Debbie KENNEDY261
KING - Telephone message for Margie GOLDSCHMIDT262
PARSONS - Attempt message for Neil GOLDSCHMIDT (fax machine on)263
PARSONS - Attempt message for Ruth Ann DODSON
PARSONS - Attempt message for Debbie YOUMANS (both # disconnected)
KING - Telephone interview with Todd SHANKS264
PARSONS/KING - Telephone interview with Robert KIM 2nd 265
PARSONS/KING - Telephone interview with Chaplain Ed STELLE266
MINNIS/KING MALIN (LEDS) letter response267
July 17, 2007
PARSONS - telephone contact with Lt. MCCAIN
PARSONS/KING - Interview of Lee GRAHAM268
PARSONS/KING - Interview of Christy LEONHARDT269
KING Preparation of Christy LEONHARDT Affidavit
ANGLEMIER Research statutory rape, statute of limitations
July 18, 2007
KING Telephone interview with KENNEDY270
ANGLEMIER Research Memo statutory rape, statute of limitations271
July 19, 2007
ANGLEMIER - Case Review
258
Ex A2o
Ex A5h
260
Ex A16c
261
Ex A20c
262
Ex A21c
263
Ex A22c
264
Ex A36a
265
Ex A1d
266
Ex A34a
267
Ex A5i
268
Ex A37a
269
Ex A29d
270
Ex A20d
271
Ex A6b
259

Investigation #2
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1/16/2008

July 20, 2007
KING Phone interview with KENNEDY#2273
KING KENNEDY Affidavit preparation
July 23, 2007
TWEEDT Case Review
July 24, 2007
PARSONS hand delivered business card to Neil GOLDSCHMIDT residence274
KING - Certified letters to Neil GOLDSCHMIDT275, Margie GOLDSCHMIDT, Tom
GIUSTO277, Debbie YOUMANS 278and OSP Captain KOK
KING - Email to DOJ Watch Center on contact info for MCINTIRE
KING - Email to/from Lt. MCCAIN on 07 16 07 interviews for CORTADA, RADER,
McGILL, CHRISTIAN and OTT.
KING - Email to Lt. MCCAIN on employee transfer from Gresham PD to MCSO
KING - Email DOJ Watch Center info on Margies brothers in Washington and Canada
to PARSONS for follow up.
TWEEDT Case Review
July 25, 2007
KING Certified Mail Return Receipt KOK
KING Review faxed Affidavit from Christy LEONAHRDT
July 26, 2007
PARSONS/KING - Interview of Marshall ROSS279
PARSONS/KING - Interview of Dave RADER280
PARSONS/KING - Interview of Jason GATES281
PARSONS/KING - Interview of Deirdre MCGILL282
PARSONS/KING - Interview of Sean CHRISTIAN283
KING Certified Mail returned YOUMANS, forwarding address284
KING Certified Mail Return Receipt - GIUSTO285
272
Ex A2p
Ex A20e
274
Ex A22e
275
Ex A22b
276
Ex A21b
277
Ex A17e
278
Ex A19b
279
Ex A41a
280
Ex A40a
281
Ex A44a
282
Ex A43a
283
Ex A42a
284
Ex A19c
285
Ex A17f
273

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KING Email to/from Christy LEONHARDT Draft Affidavit

KING Receipt of phone message from Margie GOLDSCHMIDT286
KING Receipt of phone message from Neil GOLDSCHMIDT287
July 27, 2007

PARSONS/KING - Interview of Rafael CORTADA288
PARSONS/KING - Interview of Christine KIRK289
KING Email Christy LEONHARDT - Draft Affidavit
KING Certified Mail Return Receipt Margie GOLDSCHMIDT290
KING Certified Mail Return Receipt Neil GOLDSCHMIDT291
July 30, 2007
PARSONS/KING - Telephonic interview of Robert BURTSCHAELL292
PARSONS/KING - Telephonic interview of David YADEN293
PARSONS/KING - Telephonic interview of Robert KIM #3294
PARSONS/KING - Telephonic interview of Margie GOLDSCHMIDT295
PARSONS - Phone message to Alice TATE
PARSONS - Phone message to Jacquenette MCINTIRE
KING - Return message from MCINTIRE
KING Review YORKs polygraph examination results of LEONHARDT
July 31, 2007
KING - Return calls from TATE
KING - Email to MCCAIN email addresses for MCSO
KING - Email to MCCAIN KIM complaint 2.a
KING - Email to MCCAIN KIM complaint 2.b.
KING - Email to MCCAIN KIM complaint 2.c.
KING - Email to MCCAIN scheduling interviews for 08 02 07
KING Letter sent to YOUMANS, new address297
286
Ex A21d-e
Ex A22c
288
Ex A46a
289
Ex A45a
290
Ex A21f
291
Ex A22d
292
Ex A47a
293
Ex A48a
294
Ex A1e
295
Ex A21g
296
Ex A2q
297
Ex A19d
287

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August 1, 2007
KING - Interviewed Roger WOOD298
KING - Emails to/from MCCAIN KIM Complaint 2.a
KING - Emails to/from MCCAIN KIM Complaint 2.b
KING - Emails to/from MCCAIN KIM Complaint 2.c.
KING - Emails to/from MCCAIN scheduling interviews
KING - Emails to/from MCCAIN MCSO email addresses
KING Review Christy LEONHARDT Affidavit
TWEEDT Case Review
August 2, 2007
PARSONS Interview Tim WONACOTT299
PARSONS - Message left for Senator BURDICK
PARSONS - Message left for Tom IMESON
PARSONS/KING - Interview Alice TATE300
PARSONS/KING Interview Jose TORRES301
PARSONS/KING Interview Bobby ODONNELL302
PARSONS - Message left for Lisa NAITO
PARSONS - Appt scheduled with Jim JEDDELOH for 08 06 07
PARSONS Message for McINTIRE
August 3, 2007
TWEEDT Case Review
PARSONS Email regarding business card drop-off at Neil
GOLDSCHMIDTs residence304
August 6, 2007
KING - Email to MCCAIN on 08 09 07 Interviews
PARSONS/KING - Interview JEDDELOH305
PARSONS/KING - Interview IMESON306
PARSONS/KING - Interview MCINTIRE307
TWEEDT Case Review
PARSONS Email to KING Interview date with NAITO308
298
Ex A50a
Ex A53a
300
Ex A38b
301
Ex A52a
302
Ex A51a
303
Ex A2r
304
Ex A22e
305
Ex A32b
306
Ex A24a
307
Ex A33d
308
Ex A16d
299

Investigation #2
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1/16/2008

August 7, 2007
KING - Case preparation
KING Review OLSEN IA
KING Review OLSEN Independent Review
KING Review RADER/CORTADA IA
KING Review of BURTSCHAELL, KIM, CORTADA, KIRK, GATES, McGILL,
CHRISTIAN, ROSS, RADER transcripts
KING Email to PARSONS, validate transcripts by reviewing audio files of interviews.
KING Email to ANGLEMIER, review of initial summaries for content accuracy and
footnote accuracy
TWEEDT Case Review
KING Email to Investigative Team - Update309
August 8, 2007
PARSONS/KING - Interview YOUMANS310
Message for OTT
PARSONS/KING - Meet with Page MCBETH
KING Review of DOJ CHL report
KING Review of DOJ ELLIOTT Interview
KING Review of TATE, TORRES, WOOD, YADEN, WONACOTT transcripts
KING Research Garr NIELSENs contact information Eureka Police Dept
KING Review Clackamas Co. DA review of JEDDELOH incidents
KING Email Investigative Team Update 311
August 9, 2007
PARSONS/KING - Interview GRAHAM #2312
PARSONS/KING - Interview NAITO #2313 NOELLE document received314
PARSONS/KING - Interview WALLS315
PARSONS/KING Interview MOORE316
PARSONS/KING Interview Jennifer OTT317
PARSONS/KING Interview WALLIKER318
KING - Discussion with KOK research GIUSTOs employment
KING Certified Mail Return Receipt YOUMANS319
TWEEDT Case Review
309
Ex A2s
Ex A19e
311
Ex A2t
312
Ex A37b
313
Ex A16e
314
Ex A16f
315
Ex A55a
316
Ex A59a
317
Ex A25b
318
Ex A61a
319
Ex A19d
310

Investigation #2
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1/16/2008

August 10, 2007
TWEEDT Case Review
August 13, 2007
PARSONS/KING - Interview Gregg KANTOR320
PARSONS/KING - Interview of Deputy Mark HERRON321
PARSONS/KING - Interview of Detective Jay PENTHENY322
KING - Phone message for Senator BURDICK
KING Review YOUMANS, GOLDSCHMIDT, IMESON, OTT, JEDDELOH,
McINTIRE GRAHAM, WALLIKER transcripts
KING Email Investigative Team Update Schedule news media letters323
KING Review KOK Response
ANGLEMIER - Case Review
August 14, 2007
KING - Certified Mail to:
Angela VALDEZ, Willamette Week
Nigel JAQUISS, Willamette Week
Les ZAITZ, Oregonian
Harry ESTEVE, Oregonian
Brent WALTH, Oregonian
Arthur Gregg SULZBERGER, Oregonian
Kimberly WILSON, Oregonian
Jeff MAPES, Oregonian
Aimee GREEN, Oregonian
Ryan GEDDES, Portland Tribune
Phil STANFORD, Portland Tribune
Jacob SANDERS, Portland Tribune
Nick BUDNICK, Portland Tribune
KING Email Investigative Team Update news media letters324
August 15, 2007
TWEEDT Case Review
KING Email to TWEEDT research revocation impact on sheriff eligibility
320
Ex A23a
Ex A57a
322
Ex A58a
323
Ex A2u
324
Ex A2v
321

Investigation #2
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1/16/2008

August 16, 2007
LORANCE/KING met with KULONGOSKIs legal counsel request interview
TWEEDT Case Review
PARSONS/KING interview of Senator Ginny BURDICK325
August 17, 2007
KING Review NAITO, HERRON, PENTHENY, MOORE and RITCHIE transcripts
PARSONS/KING Interview BUDNICK
KING - Email Investigative Team Update 326
August 20, 2007
TWEEDT Case Review
KING Case Preparation
August 21, 2007
ANGLEMIER Case Preparation Questions
TWEEDT Case Review
August 22, 2007
ANGLEMIER Case Preparation Questions
TWEEDT Case Review
August 23, 2007
ANGLEMIER Case Research statutory rape and statute of limitations327
ANGLEMIER Memorandum, Follow up to research statutory rape and statute of
limitations
August 24, 2007
KING/ANGLEMIER Review of statute of limitations
KING Research on GOLDSCHMIDT328
KING Review of KANTOR, BURDICK and BOTTOMLY transcripts
KING/LORANCE review of REESE letter re: KULONGOSKI
LORANCE preparation of response to REESE
TWEEDT/ANGLEMIER/KING preparation of KULONGOSKI questions
KING - Email Investigative Team Update329
ANGLEMIER Interview summary validation
TWEEDT Case Review
KING/TWEEDT email on confidentiality re: KENNEDY (Stone)330
325
Ex A54a
Ex A2w
327
Ex A6c
328
Ex A22f
329
Ex A2x
326

Investigation #2
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KING Email to KENNEDY with draft affidavit331
August 28, 2007

August 29, 2007
August 30, 2007
August 31, 2007
September 2, 2007
PARSONS Audio transcription validation
September 3, 2007
September 6, 2007
September 7, 2007
TWEEDT Case Review
September 10, 2007
September 14, 2007
LORANCE/KING review KULONGOSKIs response to questions
KING Letter to KIM GIUSTO332
KING Letter to James HINKLEY333
KING Letter to GEISTWHITE334
KING Letter to BRANT335
September 15, 2007
330
Ex A20f
Ex A20g
332
Ex A65A
333
Ex A66a
334
Ex A67A
335
Ex A68a
336
Ex A2y
331

Investigation #2
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1/16/2008
KING Email to TWEEDT impact of revocation on currently elected Sheriff337
September 17, 2007

PARSONS/KING Interview of OLSEN338
PARSONS/KING Interview of ELLIOTT339
TWEEDT Email to King impact of revocation on currently elected Sheriff340
September 18, 2007
TWEEDT Case Review
September 19, 2007
September 21, 2007
KING Certified Mail Return Receipt undeliverable HINKLEY
KING Review of ELLIOTT transcript
KING Email to KENNEDY, follow up on Affidavit342
September 24, 2007
KING Email to/from DOJ Watch Center Contact information for HINKLEY
KING Email to ANGLEMIER research on CHL
TWEEDT Case Review
PARSONS Email to KING Gresham city councilwomen343
September 25, 2007
ANGLEMIER Case Research CHL
TWEEDT Case Review
KING Email to ANGLEMIER research on fact pattern
September 26, 2007
ANGLEMIER Case Research CHL344
337
Ex A4a
Ex A56c
339
Ex A64a
340
Ex A4a
341
Ex A2z
342
Ex A20h
343
Ex A49a
344
Ex A6d
338

Investigation #2
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1/16/2008
September 27, 2007

KING Letter to HINKLEY (second)
KING Email to Investigative Team Update345
September 28, 2007
PARSONS/KING email to/from DOSS346
October 1, 2007
PARSONS/KING Interview of DOSS347
PARSONS/KING Interview of GIUSTO348
October 2, 2007
October 3, 2007
KING Email to/from BUTTS349
KING Email to Investigative Team Draft Report350
KING Email to ANGLEMIER Brady issues
October 4, 2007
Investigative Team Meeting
KING Phone interview with GIUSTO, KIM351
PARSONS/KING Phone interview with Debby NOAH352
PARSONS/KING Phone interview with Vicky THOMPSON353
PARSONS/KING Phone interview with Garr NIELSEN354
PARSONS/KING Phone interview with James HINKLEY355
KING Letter to GIUSTO regarding PPC356
KING Email to Investigative Team Update
345
Ex A2aa
Ex A72c
347
Ex A72b
348
Ex A3d
349
Ex A69c, A69d
350
Ex A2bb
351
Ex A65c
352
Ex A70c
353
Ex A71c
354
A39c
355
Ex A66g
356
Ex A3c
346

Investigation #2
Page 106 of 302
1/16/2008

October 5, 2007
KING Email to Investigative Team Update357
KING Letter to Giusto on Police Policy Committee358
October 8, 2007
KING Investigate Team Update
KING Case preparation
KING Review DOSS, ODonnell transcripts
KING Review GRAHAM Affidavit
PARSONS Audio transcript validation
ANGLEMIER Research Brady issues
ANGLEMIER Research - restraining order requirements
October 9, 2007
PARSONS Audio transcript validation
KING Case preparation
ANGLEMIER Research restraining order requirements359
ANGLEMIER Research Government Standards and Practices Commission360
KING Receipt Certified Mail Return Receipt - NIELSEN
October 10, 2007
KING Prepare interview summaries
PARSONS Validate Audio to transcripts
October 11, 2007
KING Prepare interview narrative summaries
PARSONS Validate Audio to transcripts
ANGLEMIER Validate narrative summaries
LORANCE Media research
KING Letter to MCCAIN Return of personal employee information361
October 12, 2007
KING Email to MCCAIN - Public Information Request362
PARSONS Media research
ANGLEMIER/LORANCE Truthfulness and Public Safety Professionals Court
Decisions363
October 13, 2007
357
Ex A2cc
Ex A3C
359
Ex A6f
360
Ex A6g
361
Ex A27gg
362
Ex A27hh
363
Ex A6h
358

Investigation #2
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1/16/2008
KING/PARSONS/LORANCE Case preparation

PARSONS Hotels of the World364
PARSONS Four Seasons Hotels365
PARSONS Fairmont Olympic Hotel366
October 14, 2007

KING/PARSONS/LORANCE Case preparation
October 15, 207
KING/PARSONS/LORANCE/TWEEDT/ANGLEMIER Case preparation
October 16, 2007
KING/LORANCE/ANGLEMIER Case preparation
October 17, 2007
KING/LORANCE Case preparation
KING Review Victoria TAFT talkshow
KING call from MCCAIN preparation for review of Draft Staff Report
October 18, 2007
KING/MCCAIN/LORANCE review of Draft Staff Report
October 22, 2007
MCCAIN advises he is now legal counsel for GIUSTO, phone message and letter367
October 23, 2007
PARSONS Case review
October 24, 2007
PARSONS Case review
October 30, 2007
PARSONS Case review
October 31, 2007
November 5, 2007
364
Ex A73c
Ex A73d
366
Ex A63e
367
Ex A27kk
365

Investigation #2
Page 108 of 302
1/16/2008

November 7, 2007
November 8, 2007
November 13, 2007
November 15, 1007
ANGLEMIER GIUSTOs response
LORANCE GIUSTOs response
TWEEDT GIUSTOs response
November 16, 2007
November 20, 2007
November 21, 2007
November 28, 2007
ANGLEMIER Case preparation
PARSONS Case preparation
LORANCE Case preparation
November 29, 2007
December 3, 2007
December 4, 2007
December 6, 2007
December 10, 2007
ANGLEMIER legal research
December 12, 2007

Investigation #2
Page 109 of 302
1/16/2008
ANGLEMIER Legal Research
December 13, 2007

ANGLEMIER Legal Research
December 21, 2007
January 4, 2007
LORANCE Receipt of Email from McCAIN, attached Oregon State Bar letter
January 7, 2008
January 8, 2008
January 9, 2008
KING/LORANCE Email from/to McCAIN, mailed requested information
January 10, 2008
January 11, 2008
January 14, 2008
KING/ANGLEMIER/LORANCE Case Preparation

Investigation #2
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1/16/2008

H. Interview Sequence, Questions, Summaries and Validation
The interview questions were provided as a guideline to identify general areas of investigatory
discussion. The method of interview, the sequence of questions, and the ultimate questions
remain the prerogative of the lead interviewer, PARSONS.
After each recorded interview or telephone message, a transcript was prepared by Business
Support Services of Salem, a private company not affiliated with DPSST or DOJ. PARSONS
validated the transcripts by comparing them to the audio recording. KING prepared interview
summaries, based on the validated transcripts. ANGLEMIER validated KINGs summaries by
comparing them to the transcripts.
1. Interview Sequence
Interviewee
Robert KIM
Fred LEONHARDT
Tom GIUSTO
Helen (Foster) BICART
Bruce MCCAIN
Debbie (Stone) KENNEDY
Chaplain Ed STELLE
Todd SHANKS, Union Pres
Christy LEONHARDT
Lee GRAHAM
Marshall ROSS
Dave RADER
Deirdre McGILL
Sean CHRISTIAN
Jason GATES
Neil GOLDSCHMIDT
Rafael CORTADA
Christine KIRK
Margie GOLDSCHMIDT
Robert BURTSCHAELL
David YADEN
Roger WOOD
Chaplain Alice TATE
Tim WONACOTT
Bobby ODONNELL
Jose TORRES
Jim JEDDELOH
Tom IMESON
Jacquenette McINTIRE
Debbie YOUMANS

Investigation #2
Page 111 of 302
Date
05 22 07, 07 16 07, 07 30 07
06 19 07
06 21 07
06 26 07
06 28 07
07 16 07, 07 18 07, 07 20 07
07 16 07
07 16 07
07 17 07
07 17 07, 08 09 07
07 26 07
07 26 07
07 26 07
07 26 07
07 26 07
07 26 07
07 27 07
07 27 07
07 30 07
07 30 07
07 30 07
08 01 07
08 02 07
08 02 07
08 02 07
08 02 07
08 06 07
08 06 07
08 06 07
08 08 07
1/16/2008

Lisa NAITO
Ned WALLS
Kathy WALLIKER
Tim MOORE
Jennifer OTT
Mark HERRON
Jay PENTHENY
Gregg KANTOR
Brent RITCHIE
Senator Ginny BURDICK
Governor Ted KULONGOSKI
Diana OLSEN
Brett ELLIOTT
Lee DOSS
Bernard GIUSTO
KIM GIUSTO
Cathy BUTTS
Garr NIELSEN
Vickie THOMPSON
Debra NOAH
James HINKLEY
Richard GEISTWHITE
Ruth Ann DODSON
MEDIA
John BRANT
Nick BUDNICK
Jeff MAPES
Brent WALTH
Harry ESTEVE
Les ZAITZ
Ryan GEDDES
Amiee GREEN
Jacob SANDERS
Phil STANFORD
Angela VALDEZ
Kimberly WILSON

Investigation #2
Page 112 of 302
06 12 07, 08 09 07
08 09 07
08 09 07
08 09 07
08 09 07
08 13 07
08 13 07
08 13 07
08 13 07
08 16 07
09 05 07
09 17 07
09 17 07
10 01 07
10 01 07
10 04 07
10 03 07 email
10 04 07
10 04 07
10 04 07
10 04 07
1/16/2008
2. Helen (Foster) BICART Questions

Background
According to an anonymous email received by MINNIS, BICART may have knowledge of
GOLDSCHMIDTs crime through GIUSTO when BICART and GIUSTO were friends.
1.
2.
3.
4.
5.
6.
How long have you known Bernard GIUSTO

Where did you first meet
When did you first meet
Describe your relationship with Bernard GIUSTO
Describe how your relationship may have changed with your changing roles
Did GIUSTO ever tell you about any crime that he was aware of regarding Neil
GOLDSCHMIDT
7. If so, what did he tell you
8. When did he tell you this
9. Have you told any other person
10. If so, whom, when and what
3. Helen (Foster) BICART Interview Summary

On June 26, 2007, PARSONS contacted BICART for the purpose of fact finding. When
asked if BICART had knowledge of whether GIUSTO knew about Neil
GOLDSCHMIDTs crime while BICART and GIUSTO were friends, BICART stated
that it never came up in conversation and they never talked about the subject. End of
interview.

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4. Therese BOTTOMLY, Oregonian

1. DPSST asks for the names and contact information of any sources that can provide
first-hand factual information in this matter.
2. In the alternative, DPSST asks that you contact your sources, if any, and ask that they
contact us.
5. Therese BOTTOMLY, Oregonian Message Summary
Hi, its Theresa Bottomly at the Oregonian. Im one of the managing editors here . . . were not
able to take part in any investigation or turn over names or anything else. As you might imagine,
we have to stay independent of any investigation. So our stories speak for themselves . . . 368
368
Ex A62o

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6. John BRANDT (freelance writer)

contact us.

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7. Nick BUDNICK, Portland Tribune

contact us.
Follow up questions related to news article quotes:
(Ex. A12.115) Giusto told reporters he had not been aware of Jeddelohs criminal background .
. .when he approved his application.
1.
2.
3.
4.
5.
6.
7.
8.
Identify the newspaper article by date and title

Confirm the author
Determine if there was more than one author
Determine if the author is the individual who interviewed Giusto, if not who did
Determine if the interview was conducted via phone or in person
Determine if there were any other individuals present during the interview
Determine if the interview was recorded; and if so, if the recording has been retained
Determine if there were notes of the conversation taken and if so, who took the notes,
and if retained
Determine the timeframe from when the interview was conducted until the article was
written (current memory)
10. Determine if the quotes accurately reflect the words of Giusto
11. Determine the context, such as, in response to a question, or other
9.

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8. State Senator Ginny BURDICK Interview Questions

Background
BURDICK and LEONHARDT met for coffee. BURDICK told reporters that LEONHARDT had
specific and detailed information about the crime.
1. Describe your career as a state senator, and your duties
2. What was your career choice prior to this position
3. Have you ever met Neil GOLDSCHMIDT
4. If so, when and under what circumstances
5. Describe your relationship with him
6. Have you ever met any family members of Neil GOLDSCHMIDT
7. If so, who had under what circumstances
8. If so, describe your relationship with them
9. Have you ever met Ted KULONGOSKI
12. Have you ever met any family members of his family
13. If so, who had under what circumstances
14. If so, describe your relationship with them
15. How did you first learn of GOLDSCHMIDTs misconduct?
16. What did you learn
17. From whom?
18. When did you learn this information?
19. How long have you known LEONHARDT
21. At the point of your fist contact with LEONHARDT, did you contact him or did he
contact you?
22. What did LEONHARDT tell you about GOLDSCHMIDTs misconduct
23. Did LEONHARDT tell you how he came about having knowledge of this information?
24. Did LEONHARDT tell you that GIUSTO had told him about GOLDSCHMIDTs
misconduct
25. Did LEONHARDT tell you when he had learned of this information from GIUSTO
26. Did LEONHARDT tell you about this information prior to, or after, the information
being made available in the media.
27. Do you have any additional information that you think we should know

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9. State Senator Ginny BURDICK Interview Summary

On August 16, 2007, PARSONS and KING interviewed BURDICK at her residence to
determine what information she had regarding the KIM and LEONHARDT allegations.
After providing BURDICK an overview, she was asked if she knew Neil GOLDSCHMIDT.
BURDICK stated she was his press secretary on his campaign in 1986.369
When asked if GOLDSCHMIDT shared information about his crime with her, BURDICK stated
she had not, that she had learned about it from the Willamette Week which called her about three
days prior to running the story. BURDICK stated the Willamette Week asked her to come in.
When they asked her if she knew anything, she was in a state of shock.370
When asked if BURDICK knew LEONHARDT, she stated she did. BURDICK stated that she
spoke with LEONHARDT after she spoke with the Willamette Week and after it was published
she had lunch with LEONHARDT. At lunch LEONHARDT told her what he knew about the
GOLDSCHMIDT crime. BURDICK stated that as she recalls LEONHARDT told her that he
had learned about GOLDSCHMIDTs crime while he was in the governors office. She stated
there was some party or something that he went to where Bernie it was either said about
Bernie or Bernie said it.
When asked if LEONHARDT told BURDICK that he had relayed information about
GOLDSCHMIDTs crime to KULONGOSKI, BURDICK sated that he said that Ted knew it. . .
he felt very strongly that Ted knew it.371
BURDICK recalled speaking to Debby KENNEDY about the article that had come out. When
asked if KENNEDY said anything to BURDICK about having knowledge of
GOLDSCHMIDTs crime, BURDICK said that KENNEDY told her that GIUSTO had told her
about it.372 BURDICK stated she knows KENNEDY as one who tells the truth.
When asked when GIUSTO told KENNEDY about the GOLDSCHMIDT crime, BURDICK
believed it to be a long time ago. When asked if KENNEDY had maintained her relationship
with GIUSTO, BURDICK recalled that KENNEDY was distressed with him.373
BURDICK confirmed that KENNEDY and GIUSTO had a relationship at one time and that it
had since ended, but that it had occurred a number of years ago. When asked if BURDICK
thought it was more likely that GIUSTO had told KENNEDY about the GOLDSCHMIDT crime
during their relationship rather than more recently, BURDICK concurred.374
369
Ex A54a, p 3
Ex A45a, p 4
371
Ex A54a, p 5
372
Ex A54a, p 7
373
Ex A54a, p 7
374
Ex A54a, p 8
370

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BURDICK stated that she and KENNEDY have been friends for over twenty years. When asked
if she believed KENNEDY was a truthful person and if she would assume she was telling the
truth about what GIUSTO had told her, BURDICK stated she would believe her.
BURDICK stated she has known LEONHARDT for a number of years, but could not recall how
she met him. BURDICK recalled LEONHARDT was a speech writer for GOLDSCHMIDT.
When asked if BURDICK believed that LEONHARDT was credible, she stated that it was
unclear in this case because he was so personally distressed by the information and she did not
know how much bearing it would have on his credibility.375
BURDICK thought that what had provoked LEONHARDT was when KULONGOSKI
appointed GOLDSCHMIDT to the Higher Ed Board. When asked if LEONHARDT wanted
BURDICK to do something about it when he had met with her, BURDICK believed
LEONHARDT was just venting.376 BURDICK stated that when GOLDSCHMIDTs crime was
revealed a lot of people were shocked, angry and devastated and that is the spirit in which I took
Freds.. . .contact.
When asked if BURDICK ever spoke with KULONGOSKI about GOLDSCHMIDTs crime,
BURDICK said she did not. When asked if Willamette Week provided their sources to her when
they spoke with her about their knowledge, BURDICK stated that she was a former reporter and
she did not even ask.377 When asked if BURDICK believed the newspaper was in the fact
finding stage or certain of their sources, BURDICK stated that the newspaper was beyond the
fact finding stage, that their story was complete and that they were looking for verification.378
When asked if the Willamette Week provided BURDICK the details, and when she later spoke
with LEONHARDT if she could form an opinion regarding whether LEONHARDT had prior
knowledge or had just read about it in the newspaper, BURDICK stated she had a sense that
something had gone on in the governors office. 379 When asked if LEONHARDT told her if
GIUSTO was the one who told him, BURDICK stated that she knew GIUSTO was involved, and
thinks LEONHARDT did tell her, but cannot remember.
When asked if BURDICK knew KIM, she stated she does not recall meeting him, but could
have. BURDICK was asked to review a matrix that the investigators had to determine if there
were any individuals that she had not been asked about. When asked if she ever spoke to Ruth
Ann DODSON about the GOLDSCHMIDT crime, she indicated she had not.380
BURDICK stated that she had spoken in general terms to Margie GOLDSCHMIDT but did not
ask her any details. When asked what KENNEDY had told her about the information GIUSTO
related to her, BURDICK stated that the girl was underage.381 When asked if KENNEDY knew
375
Ex A54a, p 9
Ex A54a, p10
377
Ex A54a, p 12
378
Ex A54a, p 13
379
Ex A54a, p 14-15
380
Ex A54a, p 16
381
Ex A54a, p 17
376

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the identity of the girl, BURDICK stated she did not disclose it to her and did not act like she
knew it.382
When asked if BURDICK had any additional information, BURDICK stated that although she
had third-hand information, she stated Fred told her he knew about the GOLDSCHMIDT crime
while [working] in the governors office.383
End of conversation
382
383
Ex A54a, p 18
Ex A54a, p 19

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10. Robert BURTSCHAELL Interview Questions

Background:
BURTSCHAELL was GOLDSCHMIDTs friend and confidant. According to one news article
BURTSCHAELL and GOLDSCHMIDT were secretly meeting with the victim.
1. How long have you known Neil GOLDSCHMIDT
3. Did you ever work for him
4. Have you ever met GIUSTO
6. If so, describe your relationship with GIUSTO
7. Has it changed with the changing roles
8. Have you ever met LEONHARDT
10. If so, describe your relationship with LEONHARDT
11. In your opinion, what was the relationship between GIUSTO and LEONHARDT
12. In your opinion, what was the relationship between GIUSTO and GOLDSCHMIDT
13. Prior to the disclosure by the media of GOLDSCHMIDTs misconduct, did you have
any prior knowledge of any information relating to the misconduct,
14. If so, how, who, when
15. Was LEONHARDT in a position to be a confidant of GOLDSCHMIDT or GIUSTO
16. Have you ever met the victims mother
17. If so, when did you meet her and what were the circumstances in which you met her
18. Describe your relationship with the victims mother
19. Where did the victims mother work, was it in state or city government?
20. If so, did she work in the GOLDSCHMIDTs administration at any time
21. If so, was this a paid position or a volunteer position
22. Have you ever met the victim
24. Describe your relationship with the victim
25. Do you recall a time when you and GOLDSCHMIDT were in a social setting, perhaps
with another individual, and the victim and Neil contacted one another
26. If so, what do you recall
27. What did the victim say
28. What did Neil say
29. Would there be any reason that LEONHARDT might disclose the information he
learned from GIUSTO now?

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11. Robert BURTSCHAELL Interview Summary

On July 30, 2007, PARSONS and KING spoke with BURTSCHAELL over the telephone to
determine what information he may have regarding allegations against GIUSTO.
BURTSCHAELL acknowledged being friends with Neil GOLDSCHMIDT but stated that he did
not know GIUSTO. BURTSCHAELL stated he did not know LEONHARDT, but may have met
him.384
When asked when BURTSCHAELL first became aware of GOLDSCHMIDTs crime, he stated
in the 80s. 385
BURTSCHAELL stated that a friend of his had run into a woman in a bar and the woman was
drunk. The woman was talking about having sex with GOLDSCHMIDT when he was the mayor
and she was a young girl. BURTSCHAELL stated he knew Neil GOLDSCHMIDT and knew
the girls parents. BURTSCHAELL stated he had been in AA for over 37 years and decided the
woman needed help. BURTSCHAELL stated that he went to GOLDSCHMIDT and faced him
up with this. BURTSCHAELL said GOLDSCHMIDT about fell over and told
BURTSCHAELL he was the first person he had ever talked to about the matter.
BURTSCHAELL stated that he and GOLDSCHMIDT began to help the woman386.
BURTSCHAELL stated that he met with the woman and began to take her to [AA] meetings,
helped her get out of some of her beefs and helped her to get jobs. BURTSCHAELL stated
the woman was about twenty-seven years old.387
When asked if GOLDSCHMIDT had told BURTSCHAELL what the young girls age was at the
time of the crime, BURTSCHAELL stated they never talked about age until it became public and
then GOLDSCHMIDT said that her age was fifteen.388
When asked if GOLDSCHMIDT had ever mentioned to him that GIUSTO may have used his
knowledge about the relationship between GOLDSCHMIDT and the young girl to his advantage,
BURTSCHAELL stated GOLDSCHMIDT never mentioned that to him, nor did
GOLDSCHMIDT ever mention whether he knew if GIUSTO did have this knowledge.389
When asked where LEONHARDT would have received his knowledge about the
GOLDSCHMIDT crime, BURTSCHAELL stated he didnt know where LEONHARDT would
have received it. When BURTSCHAELL was asked if the individual that provided him the
original information would be willing to talk to investigators, BURTSCHAELL stated nope.390
384
Ex A47a, p 3
Ex A47a, p 4
386
Ex A47a, p 6
387
Ex A47a, p 7
388
Ex A47a, p 9
389
Ex A47a, p 10
390
Ex A47a, p 10
385

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BURTSCHAELL confirmed that his friend contacted him because he knew BURTSCHAELL
knew GOLDSCHMIDT.391
When asked if he was involved in paying the victim not to say anything to the authorities,
BURTSCHAELL denied it and stated that neither he nor GOLDSCHMIDT paid the victim.
BURTSCHAELL confirmed that the victim was assisted by her parents to obtain services.
BURTSCHAELL confirmed his role was that of a mentor regarding the victims drug and
alcohol issues.392
When asked if BURTSCHAELL knew KULONGOSKI, he stated he had met KULONGOSKI;
but that he does not know him.
When asked if BURTSCHAELL knew if KULONGOSKI was aware of GOLDSCHMIDTs
crime, he stated he did not know. When asked if BURTSCHAELL ever discussed with
GOLDSCHMIDT whether KULONGOSKI knew of GOLDSCHMIDTs crime
BURTSCHAELL stated no.393
BURTSCHAELL inquired about GIUSTO, the statute of limitations, whether GIUSTO used his
knowledge to gain an advantage in his career, and the DPSST certification standards.394
BURTSCHAELL summarized his conversation with PARSONS by stating he believed the best
person to help him help the woman was Neil GOLDSCHMIDT, that he asked GOLDSCHMIDT
to help him help her and GOLDSCHMIDT did so.395 BURTSCHAELL did not believe he and
GOLDSCHMIDT and GIUSTO were ever all together.396 BURTSCHAELL believed that
because he was GOLDSCHMIDTs confidant, he would have been told by GOLDSCHMIDT if
GOLDSCHMIDT knew that GIUSTO knew about the woman, or attempted to use the
information to gain an advantage.
During the conversation, BURTSCHAELL asked if the conversation was being recorded.
PARSONS stated that it was.397 At the end of the conversation, BURTSCHAELL asked for a
copy of the transcript and provided his email address.398
End of conversation.
391
Ex A47a, p 11
Ex A47a, p 14
393
Ex A47a, p 15
394
Ex A47a, p 15-16
395
Ex A47a, p 17
396
Ex A47a, p 18
397
Ex A47a, p 8
398
Ex A47a, p 21
392

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12. Kathy BUTTS Interview Questions

1.
2.
3.
4.
5.
6.
How long have you served as a Gresham City Councilwoman

During your tenure there, do you recall who served as the Chief of Police
Describe your relationship with GIUSTO
Has this relationship changed
If so, explain, and why
There has been an allegation that during the time that GIUSTO was the Chief of
Gresham Police, and you served on the Gresham City Council, you and he were
involved in a relationship that allowed him to have inappropriate benefit. Is there any
validity to this allegation
7. If so, what
8. If not, why not
9. Do you ever recall a time when GIUSTO asked you for some thing, or for a decision to
be made that you would not have made had you and he not had a relationship, or that
you would not have afforded to another chief in the same position asking for the same
things
10. Is there anything else that we should know
13. Kathy BUTTS Interview Summary

Email response on October 4, 2007, I was a councilwoman in Gresham from 1999-2003 but I
did not have a personal relationship with Chief Giusto nor did the other councilwoman, Vicki
Thompson, to my knowledge. As far as Chief Giusto asking for any special benefit or gain, the
answer is no, never. . . 399
399
Ex A69d

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14. MCSO Deputy Sean CHRISTIAN Interview Questions

Background:
CHRISTIAN was named as the individual who reported contact between McGILL and GIUSTO.
1.
2.
3.
4.
5.
6.
7.
8.
How long have you served with MCSO?

What positions have you held with MCSO
When is the first time you met Sheriff GIUSTO
Under what circumstances did you meet GIUSTO
Describe your relationship with him
Has your relationship changed since you first met him
If so, how so
Do you recall a time that you became aware of communications between GIUSTO and
McGill that was other than work related
9. If so, when did you become aware of this
10. If so, how did you become aware of this
11. Have you ever seen the communications or a copy of the communications
12. If so, what do you recall the communications contained
13. At some point did another individual become aware that you knew about teh
communication(s) between GIUSTO and McGILL
14. If so, how did this occur
15. Who was/were the others
16. Did you discuss their communication(s) with another person
17. If so, who did you discuss it/them with
18. If so, what did you discuss
19. Were you offended by GIUSTOs communications with McGILL
20. If so, how were you offended
21. If not, did you have any concerns
22. If so, what concerns did you have
23. At some point did you contact someone or did someone contact you about GIUSTOs
communications with McGILL
24. If so, who was that person
25. If so, what was the discussion
26. At some point did Jennifer OTT contact you
27. If so, what was your understanding of her organizational position in the agency
28. If so, what did you and OTT discuss
29. At some point did Chief Deputy GRAHAM contact you, or did you contact him, about
this situation
30. If so, when and what was discussed
31. At any point did you hear that McGILL had been told that if she divulged GIUSTOs
communication with her, her job would some how be in jeopardy?
32. If so, who discussed this with you and what was said
33. Do you believe that this matter has been resolved?
34. If so, why or why not
35. What would you have liked to seen handled differently

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36. Have you ever met Robert KIM
37. If so, when did you meet him
38. If so, have you had occasion to be at his house
39. If so, when and how often
40. If not, do you know who he is
41. If not, have you heard any of your colleagues, or anyone else, talking about who
Robert KIMs sources might be
42. If so, who have you heard they are
15. MCSO Deputy Sean CHRISTIAN Interview Summary
On July 26, 2007, PARSONS and KING interviewed CHRISTIAN at his place of employment.
The purpose of the interview was fact finding to determine what first-hand knowledge he had
regarding the KIM allegation of GIUSTOs contact with a female employee.
After CHRISTIAN provided his employment history, he was asked when he first met GIUSTO.
CHRISTIAN stated when GIUSTO was the Chief of Gresham PD, through the special
investigations unit which includes a Gresham detective. CHRISTIAN characterized his
relationship with GIUSTO as professional.400
When asked when CHRISTIAN first became aware of the communication between McGILL and
GIUSTO, CHRISTIAN stated that McGILL told him that she had personal contact with
GIUSTO outside of work related contact. CHRISTIAN described this as McGILL mentioning a
phone call and that GIUSTO had been up in McGILLs office. When asked if CHRISTIAN had
seen GIUSTO in their offices, CHRISTIAN stated he had seen GIUSTO on the second floor but
not in McGILLs office.401
When asked if McGILL expressed any concerns, CHRISTIAN described their units difficulties,
that things were starting to really mellow outand he or someone asked McGILL if she felt
uncomfortable and if she wanted it to stop. McGill stated, no. CHRISTIAN stated that he
looked at the direction that the situation could go and even though there was no allegation of
any wrongdoing, I went down and said, you know, just stop it.402
When asked who he talked to, CHRISTIAN stated GIUSTO and GRAHAM were in the room at
the time and he told them, its not a good idea. When asked what GIUSTOs response was,
CHRISTIAN stated GIUSTO told him I appreciate your input and when GUISTO attempted to
explain himself CHRISTIAN told them he didnt need to explain anything to him. When asked
what GRAHAM said, CHRISTIAN said GRAHAM was pretty much silent.403 When asked
when this incident occurred, CHRISTIAN stated two or three years ago. When asked if
GIUSTOs interest in McGILL was going to cause problems, CHRISTIAN stated that he didnt
like hearing about it and that when a supervisor was involved it wasnt a good idea.404
400
Ex A42a, p 3
Ex 42a, p 4-5
402
Ex 42a, p 6
403
Ex 42a, p 7-8
404
Ex 42a, p 9
401

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When asked why CHRISTIAN didnt go directly to McGILL after telling GIUSTO and
GRAHAM and CHRISTIAN stated, Because it wasnt a formal thing. . . things went away . . .it
stopped. CHRISTIAN continued to explain that he believed GRAHAM and GIUSTO probably
thought they should make his concerns an actual investigation, then McGILL got interviewed
and then everything went to shit.. . .Im the jackass now for trying to do the right thing.405
When asked who contacted McGILL, CHRISTIAN thought perhaps it was Jennifer OTT. When
asked what the gist of their conversation was, CHRISTIAN stated he did not know.
When asked if McGILL told him that OTT had spoken with her, CHRISTIAN stated she did, but
McGILL did not know at the time that he had told GIUSTO and GRAHAM about his concerns.
CHRISTIAN stated that afterwards he thought about it for a little bit and said, Oh shit, just go
in and tell her.406
When asked what he had observed between McGILL and GIUSTO, he stated nothing. When
asked if he saw GIUSTO speaking to McGILL, CHRISTIAN stated, no. When asked if
McGILL told him individually or in a group setting about what had occurred between her and
GIUSTO, CHRISTIAN first stated that it was difficult to remember. CHRISTIAN then asked
that the tape recorder be turned off. When asked why he was uncomfortable with the tape being
on, CHRISTIAN stated he just wanted to throw something out.407
OFF TAPE
Taken from KINGs notes: CHRISTIAN stated that in his opinion McGILL was a drama queen
and that she sought attention from his co-workers. CHRISTIAN stated that because McGILL
was a drama queen he perceived that she was going to bring the unit under scrutiny.
BACK ON TAPE
When asked if McGILL ever called a group of detectives or deputies together to share her
concerns, but then stated she wanted to handle it on her own, CHRISTIAN stated that McGILL
never stated she was concerned, but did say she could handle this on her own. She stated, No, I
can take care of it myself..408
CHRISTIAN asked to go OFF TAPE
Taken from KINGs notes: CHRISTIAN stated that he was aware of a group of disgruntled
employees who were seeking out some of the newer members of the agency. At one point a new
deputy came to him for advice about whether to join this group of disgruntled employees.
CHRISTIAN identified Jose TORRES as a leader of the group of disgruntled employees and
stated that he was an angry guy.
405
Ex 42a, p 10
Ex A42,a, p 11
407
Ex A42a, p 12
408
Ex 42a, p 13
406

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CHRISTIAN observed that KING was continuing to take notes and stated that he might as well
go back on the record since notes were being taken.
BACK ON TAPE
CHRISTIAN stated that a younger deputy came to him, upset and scared that a group of deputies
were inviting him into their group to write a letter to overthrow the Sheriffs office.
CHRISTIAN stated that he told the deputy not to join their group and that he would take care of
it. CHRISTIAN stated that in the original complaint there were things included that were
absolutely wrong. When asked who was with TORRES, CHRISTIAN stated Rod NEWSOM,
(phonetic) who started out in the group and then blew it off.409 CHRISTAIN clarified the
group by stating it was just a bunch of guys getting together bitching.. . . .except they took it
to a point where it was kind of horseshit, where they put it on an anonymous letter into the
paper.410 When asked who else was in the group CHRISTIAN declined to respond.
When asked if he knew Robert KIM, CHRISTIAN stated he did not, and did not know anyone
that knew him. CHRISTIAN suggested investigators talk to Garr NIELSEN, that he may know
KIM or someone who knows KIM.411 CHRISTIAN then surmised that the information was not
coming out of the Hansen Building but out of the Hawthorne Building.
CHRISTIAN stated that there were only three people that knew of his conversation about
McGILL; he, GRAHAM and GIUSTO, and it was supposed to be person to person, that he
wanted to keep it confidential. CHRISTIAN stated that he then got pulled aside by Brett
ELLIOTT who asked if CHRISTIAN had a problem with the way he commanded. ELLIOTT
then asked what the deal was between you and Lee [GRAHAM]. CHRISTIAN stated that
ELLIOTT told him that GRAHAM confronted him about CHRISTIANs conversation,
including, Sean Christian didnt even want to go to you because youre not around and you
dont have control. CHRISTIAN stated he got rat fucked because after ELLIOTT confronted
him, Ned WALLS [his sergeant] confronted him about going over his head.412 CHRISTIAN
attempted to explain that it didnt have anything to do with chain of command; he just wanted it
to stop. CHRISTIAN stated that there was a leak somewhere, so that was when he told
McGILL that it was he who had reported her concern, because if ELLIOTT knew and Ned
knew, chances are theres somebody else that knows and she might as well hear it from me
first.413
When asked if OTT interviewed him about the McGILL situation, CHRISTIAN stated he had
not been interviewed and it struck him as odd. When asked if McGILL came back and told
her co-workers that she had spoken to OTT, CHRISTIAN stated McGILL had told him while he
was in her office. When asked if McGILL ever felt as if her job was in jeopardy or that she was
409
Ex A42a, p 15
Ex A42a, p 16
411
Ex A42a, p 19
412
Ex A42a, p 20
413
Ex A432a, p 21
410

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going to suffer retaliation, CHRISTIAN stated that it wasnt even under investigation. . .there
was no investigation . . .no complaint.414
When asked if he knew who had contacted Robert KIM, CHRISTIAN stated no one had come
forward as KIMs source.
When investigators returned to the topic of what he told GIUSTO about McGILL, CHRISTIAN
stated it sounded like McGILL and GIUSTO were going to get together or he he was trying -he was going to ask her out or . . .it was heading in that direction.415 When asked if
CHRISTIAN gave GIUSTO any specifics, CHRISTIAN stated that it was GIUSTO who said he
gave her two bottles of wine, asserting that McGILL had asked his opinion about wine and he
brought her wine.
When asked about his relationship with Diana OLSEN, CHRISTIAN stated they had worked
together in patrol and they stuck together because their sergeant was such a jackass they
would look out for each other.416
CHRISTIAN asked to go OFF TAPE (2 minutes)
Taken from KINGs notes: CHRISTIAN commented that MCSO was fearful of OLSEN bringing a
lawsuit against them, but he does not believe OLSEN and TORRES worked on the original letter
together because they do not like one another.
BACK ON TAPE
CHRISTIAN stated that when the [KIM] letter came out, he and OLSEN had a discussion about
it. CHRISTIAN stated OLSEN was one of those folks that knows the rules as far as days off
how to accumulate days off, and there was a target on her back. 417 CHRISTIAN stated that
management attempted to stop her from taking time off and OLSEN got an attorney. At one
point he told OLSEN that he knew it was not she who had written the original letter, even though
everyone thought it was her, because he knew TORRES and she did not get along.
End of conversation
414
Ex A42a, p 24
Ex A42a, p 27
416
Ex A42a, p 29
417
Ex A42a, p 31
415

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16. MCSO Deputy Rafael CORTADA Interview Questions

Background
This individual has been identified by GRAHAM as the deputy who was offended by the oreo
terminology, and later filed a complaint against RADER.
1.
2.
3.
4.
5.
6.
7.
8.
9.

When is the first time you met Lt. RADER
If so, how so
Do you recall a time that you were present when Lt. RADER was talking and used the
term orego?
10. If so, describe the circumstances and content of the discussion
11. Who else was present?
12. What were your thought about this discussion
13. Were you offended by Lt. RADERs use of this terminology
14. If so, why
15. What did you do about it
16. At some point did you address your concerns with another individual
17. If so, whom and when
18. What was the result of this discussion
19. What happened next
20. At some point did you have a discussion with Chief Deputy Lee GRAHAM
21. If so, what was the content of the discussion and when did it occur
22. At any point did GRAHAM tell you that Lt. RADER was remorseful and wanted to
apologize to you?
23. If so, what was your reaction
24. Did this apology take place
25. If not, why not
26. At any point did GRAHAM tell you that Lt. RADER had been disciplined regarding
his comment
27. If so, what was your reaction
28. Do you feel that this matter has been resolved to your satisfaction?

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17. MCSO Deputy Rafael CORTADA Interview Summary

On July 27, 2007, PARSONS and KING interviewed CORTADA, at his place of employment.
The purpose of the interview was fact-finding regarding his knowledge of KIMs allegations.
CORTADA had his Union representative, Brent RITCHIE, present with him.
After a review of CORTADAs employment history, CORTADA stated he had met GIUSTO
shortly after he was elected and their relationship was a professional one. When asked how long
he had known Dave RADER, CORTADA stated when he was a recruit and RADER was a
sergeant and that they maintain a professional relationship.418
When asked if RADER had ever used the terminology oreo when describing an incident,
CORTADA stated that he had been passed over at one point for a sergeants position and was
given things to work on to be looked at once again. CORTADA stated that at one roll call he
proposed an idea that would have allowed him to accomplish one of his goals and he felt
RADER put him aside. CORTADA stated that then RADER began to tell a story about a call
that he had in which he made an Oreo cookie out of somebody.419
CORTADA explained that they sandwiched a person like squeezing him onto a back board or
something like that.420 When asked what CORTADAs thoughts were when RADER was
referring to the oreo during him taking someone into custody, CORTADA stated that his
thoughts returned to being passed over for a promotional exam, trying to accomplish a goal and
being shot down, and someone at that level saying something like that.421 When asked if
CORTADA was offended by the terminology, he stated he was, and it was the entire context,
not just one thing. When asked what CORTADAs interpretation was of the term oreo that
would have a negative connotation, CORTADA stated that he grew up back east, that he came
from a very mixed background and that is not something that would be a compliment
necessarily to call somebody an Oreo.422
CORTADA confirmed that he addressed his concern with co-workers and the matter eventually
was taken to Capt ELLIOTT. When asked if someone contacted him, CORTADA stated that he
had an interview with someone in IA, there were several interviews with GRAHAM and one
with GIUSTO. 423
When asked about the context of his conversation with GIUSTO, CORTADA stated he was
asked how he wanted the situation handled and CORTADA wanted it handled according to their
SOP 6.07 manual; because it was a command officer, he wanted an outside investigation rather
than an internal one. CORTADA stated the investigation was not sent out, but handled internally
by GRAHAM, even though IA recommended that the matter be investigated by an outside
agency.424
418
Ex A46a, p 3
Ex A46a, p 4
420
Ex A46a, p 5
421
Ex A46a, p 6
422
Ex A46a, p 7
423
Ex A46a, p 8
424
Ex A46a, p 9
419

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When asked about the outcome of the investigation, CORTADA stated he was not privy to that
information regarding disciplinary action, that it was just resolved. When asked if CORTADA
met with RADER, he stated there was a meeting and that RADER apologized. When asked if
CORTADA was satisfied with the eventual outcome, CORTADA stated that he would not know
what the outcome would have been either way, but his focus was on an outside investigation
because that is what the policy stated and he did not see any grey area in the policy.425
When asked if RADER was remorseful or felt badly that he had been offended, CORTADA
stated he could not interpret RADERs feelings, that his relationship with him since then has
been professional and there have been no additional incidents.426 When asked if RADER
recognized that the term oreo was offensive to him, CORTADA stated I dont necessarily
think he knew at the time he offended me. CORTADA stated he looked at the totality of
circumstances and it was not a single word that was the negative trigger but it was in conjunction
with several events.427
When asked who was present at the meeting, CORTADA stated GRAHAM and GIUSTO, and
that the meeting was in GRAHAMs office.428 CORTADA confirmed that if things were done
differently he would have wanted an outside agency to handle the investigation. When asked if
CORTADA felt that the agency handled the complaint professionally, he stated that the people
he worked with were generally concerned and did the best they could to come up with a
resolution. CORTADA stated he has just moved on and continues to work hard in hopes of
getting an opportunity to get promoted.
RITCHIE asked CORTADA if RADER was referring to a person of color getting sandwiched
and CORTADA thought it was, if he recalled correctly.429
When asked if CORTADA knew KIM, he stated he did not. RITCHIE asked investigators why
they were asking that question and he was told that investigators were trying to find out who
knew him. RITCHIE was asked if he knew KIM and he stated no.430
425
Ex A46a, p 10
Ex A46a, p 11
427
Ex A46a, p 15
428
Ex A46a, p 12
429
Ex A46a, p 15
430
Ex A46a, p 16
426

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18. Ruth Ann DODSON Interview Questions

Background
DODSON worked closely with Neil GOLDSCHMIDT in his administration as governor and
prior to this. There is some indication that DODSON knew about GOLDSCHMIDTs crime and
communicated with the victim and or her mother on GOLDSCHMIDTs behalf.
On July 25, 2007, DODSON was mailed a letter asking that she contact investigators. DODSON
has not done so.
1.
2.
3.
4.
How long have you known Neil GOLDSCHMIDT

How has your relationship changed over the years with changing roles
When did you first become aware that GOLDSCHMIDT had been involved in a
relationship with a young woman.
5. How did you become aware of this
6. Who told you
9. How has your relationship changed over the years with changing roles
10. Did Gregg KANTOR or Tom IMESON ever come to you and tell you that they had
been told by LEONHARDT that GOLDSCHMIDT had a relationship with a young
woman
11. If so, who told you and what did they tell you
12. When did they tell you this
13. Did you tell GOLDSCHMIDT about what you were told
14. Did you have any interactions with the young woman that GOLDSCHMIDT had a
relationship with?
15. Did you have any interactions with the young womans mother
16. If so, what were the interactions and when were they
17. Do you know if GIUSTO had knowledge of these interactions
18. Were you aware that Margies brother came to Neil about his knowledge of his
relationship with the young woman
20. How did you become aware of this
21. At any point did Margie tell you that she had told GIUSTO about Neils relationship
with the young woman
22. If so, when did she tell you, and when did she say she had told GIUSTO ?

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19. Lee (Jeddeloh) DOSS Interview Questions

Background:
DOSS was formerly married to JEDDELOH, the individual who applied for the concealed
handgun license. DOSS has since developed a relationship with GIUSTO. DOSS and
JEDDELOH are divorced. The specific focus of this interview needs to be whether GIUSTO
confides in her, what he has confided regarding his knowledge of GOLDSCHMIDTs crime,
when he came to this knowledge and who he told.
Secondarily, follow up on GIUSTO and her personal emails and phone calls, and the insurance
papers that were copied on an agency computer.
Ask about DOSS and GIUSTO spending the weekend in Seattle.
20. Lee (Jeddeloh) DOSS Interview Summary
On October 1, 2007, PARSONS and KING met with DOSS for the purpose of fact finding.
When asked if GIUSTO had shared with DOSS information about GOLDSCHMIDTs crime.431
DOSS asked a series of questions about the interview and ultimately DOSS stated that GIUSTO
did not give her information.432 When DOSS was asked if GIUSTO used his knowledge of the
GOLDSCHMIDT crime to keep his position, or for promotional purposes, DOSS stated
GIUSTO had not told her that.433 When asked if GIUSTO and DOSS went to Seattle while her
husband was in rehab DOSS stated, No.434 When asked if DOSS and GIUSTO took any outof-town trips while her husband was at the Betty Ford Clinic, DOSS stated, We didnt take trips
. . .at my childrens request, he accompanied us many times. . . 435 When asked when Jim
JEDDELOH was served with the divorce papers, DOSS was unsure when he was actually
served. When asked if GIUSTO had given DOSS any insurance papers to photocopy, DOSS
stated, I have no idea what that refers to.436
431
Ex A72b, p 2
Ex A72b, p 4-5
433
Ex A72b, p 6
434
Ex A72b, p 6, line 22
435
Ex A72b, p 7
436
Ex A72b, p 14
432

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21. MCSO Capt. Brett ELLIOTT Interview Questions

Background:
ELLIOTT was supervising the concealed weapons section for MCSO when the JEDDELOH
issue occurred. ELLIOTT was told about JEDDELOHs criminal history by clerk Jeanne
BROWN. ELLIOTT provided a copy of a handwritten note by GIUSTO authorizing a permit to
be issued. Although he or Lt. RADER routinely authorized CHL, all decisions regarding the
JEDDELOHs application were made without his knowledge or input. ELLIOTT could not
recall another occurrence such as this.
ELLIOTT was also briefed by GRAHAM about GIUSTOs intervention and asked to identify
personnel to assist. ELLIOTT identified ROSS and GATES. ELLIOTT stated it was highly
unusual for GIUSTO to be involved because he does not become involved in routine law
enforcement.
ELLIOTT asserted that once a restraining order was issued, not serving it was unusual, and that
there were not exceptional circumstances preventing the service of it on JEDDELOH. ELLIOTT
asserted it was highly unusual to pick up a Portland case but it could be done with permission
from a supervisor.
After the RADER/OLSEN incident, ELLIOTT became OLSENs supervisor.
1. How long have you served with MCSO?
2. What positions have you held with MCSO
3. When is the first time you met Sheriff GIUSTO
4. Under what circumstances did you meet GIUSTO
6. Has your relationship changed since you first met him
7. If so, how so
8. I understand you were involved in the intervention matter concerning GIUSTO and
JEDDELOH
9. Do you believe you were following the explicit directions from GIUSTO and/or his
command staff
10. Do you have any concerns about this incident
11. I understand that you were involved in the application of the concealed handgun
license for JEDDELOH
12. If so, how did this application process differ from a routine process
13. Did you have any concerns about this application or the process

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21. Do you have any personal knowledge of the KIM allegation involving a failure to
investigate a racial harassment complaint against a MCSO Lt with outside
investigators.
22. Do you have any personal knowledge of the KIM allegation involving failure to
investigative misconduct against a MCSO sergeant who was involved with another
members wife?
23. Do you have any personal knowledge of the KIM allegation involving GIIUSTOs
instigation of a complaint against a female sergeant regarding the misuse of time and a
subsequent investigation by a female attorney
24. Do you have any personal knowledge of the KIM allegation involving Giusto lying to
investigators, reporters, members of MCSO or the pubic
25. Do you have any personal knowledge of the KIM allegation involving GIUSTO
violating county email policy by sending personal emails to Lee Jeddeloh DPSS
26. Do you have any personal knowledge of the KIM allegation involving GIUSTOs
contacts with Margie GOLDSCHMIDT while she was still married to Neil
GOLDSCHMIDT
27. Do you have any personal knowledge of the KIM allegation involving GIUSTO failing
to report the child abuse of Neil GOLDSCHMIDT when he became aware of it
engaging in a personal relationship with a Gresham city councilwoman
29. Do you have any personal knowledge of the KIM allegation involving GIUSTO having
improper contact with a MCSO civilian female employee
engaging in improper conduct with a female volunteer chaplain which affected the
existing male chaplains working environment
31. Do you have any personal knowledge of the KIM allegation of GIUISTO pursuing a
female PPB at a retirement for a male sergeant
32. Do you have any personal knowledge of the KIM allegation of GIUSTO making false
statements to the media about the approval of the CHL to JEDDELOH
33. Do you have any personal knowledge of the KIM allegation that GIUSTO directed his
staff to cover up the application, by either taking the file, or having it altered
34. Do you have any personal knowledge of the KIM allegation that GIUSTO manipulated
or misused the protective order of JEDDELOH, by failing to serve it properly
35. Do you have any personal knowledge of the KIM allegation that GIUSTO engage in a
personal relationship with Lee Jeddeloh DOSS in an effort to conceal his bad act in her
eyes of approving the CHL for Jim JEDDELOH
36. Do you have any personal knowledge of the KIM allegation that GIUSTO made false
statements to the media about ht nature of his relationship with Lee Jeddeloh DOSS
37. Do you have any personal knowledge of the KIM allegation that GIUSTO used MCSO
equipment to photocopy personal insurance document of Lee Jeddeloh DOSS or of her
children
38. Do you have any personal knowledge of any other misconduct by GIUSTO that has
been alleged by others, or that has been observed by you personally
39. Is there anything else that we should know or should ask you about this

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22. MCSO Captain Brett ELLIOTT Interview Summary

On September 17, 2007, PARSONS and KING met with ELLIOTT at his place of employment
to interview him regarding what he may know about the allegations against GIUSTO.
After a review of his employment background ELLIOTT stated he had known GIUSTO since
GIUSTO was the Chief of Gresham Police Department and had met GIUSTO through
interagency meetings.437 ELLIOTT described his relationship with GIUSTO as professional.
When asked about ELLIOTTs involvement in the JEDDELOH intervention, he stated
GRAHAM ordered him to have two officers present; a supervisor and a civil deputy. ELLIOTT
selected GATES and ROSS. When asked if ELLIOTT had been involved in the concealed
handgun license, ELLIOTT stated that he was indirectly involved since he would have signed
most of the concealed handgun licenses that had been refused, revoked or declined.438
ELLIOTT stated that GRAHAM was taking the JEDDELOH application through the initial
processing so he was not involved in this case. When asked if the JEDDELOH application was
an occurrence that would happen on occasion with certain citizens in the community who had
contacted GIUSTO, ELLIOTT stated that was a first and he did not recall it ever happening
before.439
When asked if ELLIOTT was subsequently involved in the application process, he stated that
staff told him that there were elements of [JEDDELOHs] background that gave them cause for
concern. ELLIOTT stated that there was an approval of the application which caused staff to
make a phone call [to JEDDELOHs residence]. ELLIOTT recalled a note on the face sheet of
the application and it was that which he provided to the Dept of Justice investigators.440
ELLIOTT stated he took the file from the section which handles handgun licenses, made a copy
and that section kept the file.441
When asked if ELLIOTT knew KIM, he stated he did not, nor did he know anyone who has
provided information to KIM. When asked if he had any personal knowledge of an allegation
regarding failure to investigate racial harassment, ELLIOTT stated he was the one who filed the
complaint against RADER by CORTADA after he met with him.442 ELLIOTT stated that was
the end of his involvement.443
When asked if ELLIOTT had personal knowledge of an allegation involving GIUSTO
instigating a complaint against a female sergeant, he stated he did not. When asked if ELLIOTT
had personal knowledge of an allegation of GIUSTO lying to investigators, reporters, members
437
Ex A64a, p 2
Ex A64a, p 3-4
439
Ex A64a, p 5
440
Ex A64a, p 6
441
Ex A64a, p 7-8
442
Ex A64a, p 9
443
Ex A64a, p 10
438

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of MCSO or the public, he stated he did not. When asked if ELLIOTT had personal knowledge
of an allegation against GIUSTO of sending personal emails to DOSS, he stated he did not.
When asked if he had personal knowledge of KIMs allegation regarding GIUSTOs failure to
report child abuse by GOLDSCHMIDT, he stated he did not. When asked if he had personal
knowledge of GIUSTO engaging in a personal relationship with a Gresham City Councilwoman
he stated he did not. When asked if he had personal knowledge of GIUSTO having improper
contact with a female MCSO civilian employee, he stated he did not.
When asked if he had personal knowledge of GIUSTOs improper conduct with a female
volunteer chaplain which affected a male chaplains working environment, he stated he did not.
When asked if he had personal knowledge of GIUSTO pursuing a female PPB employee at a
retirement party, he stated he did not.
When asked if he had personal knowledge of an allegation of GIUSTO making false statements
to the media about the approval of the concealed handgun permit, he stated he did not. When
asked to clarify that everything that he had seen in the media was accurate and complete,
ELLIOTT stated he did not know what GIUSTO provided to the media; that he would have to
look again at the media quotes.
When asked if ELLIOTT had any knowledge of GIUSTO directing any staff to cover up
something on the application by taking the file or by altering the file, ELLIOTT stated he had no
knowledge of that.444
When asked if ELLIOTT had any knowledge of GIUSTO manipulating or misusing a protective
order against JEDDELOH by failing to serve it properly, ELLIOTT stated he had found out that
a judge had issued a restraining order and in his own experience a judge issues a restraining
order to protect a person; therefore the expectation is that if issued, the order will be served.
ELLIOTT stated that if the Order was not served it would be unusual; that they have an
obligation to serve it.445
When asked if ELLIOTT had personal knowledge of GIUSTO making false statements to the
media about his relationship with DOSS, ELLIOTT stated he did not. When asked if ELLIOTT
had personal knowledge about GIUSTO using MCSO equipment to photocopy personal
documents for DOSS (JEDDELOH), ELLIOT stated he did not. When asked if there were any
of the allegations that the investigators should have more information on, or asked questions on,
ELLIOTT stated none at the time.
When asked if ELLIOTT had a personal conversation with GIUSTO about JEDDELOHs
criminal background, ELLIOTT stated he did not.446
444
Ex A64a, p 14
Ex A64a, p 15
446
Ex A64a, p 17
445

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23. Harry ESTEVE, Oregonian

contact us.

Investigation #2
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24. MCSO Lt. Jason GATES Interview Questions

Background
GATES was involved in the intervention of JEDDELOH, at the direction of ELLIOTT.
GATES is now the PIO for MCSO.
1.
2.
3.
4.
5.
6.
7.
8.

If so, how so
I understand you were involved in the intervention matter concerning GIUSTO and
JEDDELOH
command staff

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25. MCSO Lt. Jason GATES Interview Summary

On July 26, 2007, PARSONS and KING interviewed GATES at his place of employment. The
purpose of the interview was fact finding to determine what first hand knowledge he had
regarding the intervention of JEDDELOH.
After providing his employment background, GATES characterized his relationship with
GIUSTO as strictly business. When asked about the intervention GATES stated he was
informed by ELLIOTT that there would be an intervention and he was assigned to this detail.
GATES stated that he and ROSS were to meet with GIUSTO and that ROSS had a restraining
order that was going to be served on JEDDELOH at the intervention.447 GATES stated that he
did not receive any instructions from GIUSTO to arrest JEDDELOH if he didnt comply.448
GATES described his and ROSSs role as strictly as cover or backup and to serve the paper.
GATES stated he did not have any concerns about the incident or the results.
When asked if GATES knew KIM or if he knew anyone who knew KIM he stated he did not.
GATES stated he had heard a rumor that a female civilian employee from the Multnomah
building knew KIM. GATES could not recall females name and stated he understood she no
longer worked at the MCSO. GATES stated that he dismissed the rumor because he doesnt deal
in rumor but in fact in his job as the Public Information Officer (PIO).449
GATES stated that although MCSO has an open press policy and employees can talk to whoever
they wish to, there were concerns about individuals disseminating confidential information
regarding an investigation or litigation.450
447
Ex A44a, p 5
Ex A44a, p 15
449
Ex A44a, p 9
450
Ex A44a, p 11-12
448

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26. Ryan GEDDES, Portland Tribune

contact us.

Investigation #2
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27. MCSO Sheriff Bernard GIUSTO Interview Questions

1. Describe your experience as a police officer
2. Describe any experience you have as an investigator
3. Describe any training you have had as an investigator
4. Have you ever handled any internal investigations, if so, what was your role
5. Have you had occasion to handle an internal investigation in which the accused
repeatedly could not recall dates, times, conversations and events?
6. How did you handle such a situation
7. Would you consider a police officers ability to have a detailed and accurate
recollection of events an essential function of their job
engaged in deception by omission, or not providing information to ensure a complete
and accurate picture of an event, diminished or minimized misconduct or other facts
9. How did you handle such a situation
engaged in misrepresentation of facts so that they appeared other than accurate
11. If so, how did you handle such a situation
engaged in knowingly making misstatements or making misstatements and not
clarifying them so that the statement was truthful.
13. If so, how did you handle such a situation
14. Do you have SOPs with MCSO that deal with these types of misconduct
15. If so, what are they
16. Describe any experience you have in the field of sexual abuse
17. Describe any experience you have in the field of child sexual abuse
18. Describe any training you have had in the field of child sexual abuse
19. Explain what you understand a child sexual predator to be
20. Have you ever been involved in an investigation in which a child sexual predator was
investigated and found to have had only one encounter with one victim
21. Explain your understanding of child sexual predators in terms of repeat behavior
22. How long have you known Fred LEONHARDT
23. How long have you known Christy LEONHARDT
24. Do you have any independent knowledge of how many children Fred and Christy
LEONHARDT have?
25. If so, when did you meet their children?
26. If so, describe them
27. Describe your relationship LEONHARDT
28. Describe how your relationship with LEONHARDT has changed as each of your roles
have changed
29. When is the last time you spoke with LEONHARDT
30. Do you recall being at KULONGOSKIs inaugural event watching the closed circuit
television
31. Do you recall asking LEONHARDT to call you?
32. Have you ever been to LEONHARDTs home?
33. How did you know where he lived?

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34. If so, when and how often?
35. Do you recall calling LEONHARDT and offering to give him a ride from the Portland
area to Salem?
36. What was your reason for offering to give LEONHARDT a ride to Salem
37. What was the proximity between your residence and LEONHARDT?
38. Had you ever offered to drive LEONHARDT to work prior to this, or after?
39. Had LEONHARDT ever offered to drive you to work prior to this, or after?
40. Do you recall stopping to have breakfast, if so, which restaurant did you eat at?
41. Where did you and LEONHARDT stop for breakfast
42. Who selected the restaurant
43. Had you and LEONHARDT stopped at this restaurant prior to this?
44. Had you been there before?
45. Were you joined by any other person?
46. Do you recall a discussion about GOLDSCHMIDT and him engaging in misconduct
with a minor female between you and LEONHARDT
47. Who initiated the discussion
48. If so, what do you recall about this discussion?
49. Did you report this information to your employing agency, Oregon State Police
50. Did your agency have any policies regarding the documentation of information that a
police officer came to have regarding allegations of a crime against a child? If so,
what were the policies
51. Did you report this information to the agency which had jurisdiction, Portland Police
Bureau
52. Did you report this information to any district attorney?
53. Did you complete any written documentation of the allegation of a crime against a
child?
54. Were you so certain about the particulars of the alleged felony crime against a child
that you knew the statute of limitations would be an issue for prosecution
55. Did it occur to you that the crime could have taken place over a period of time rather
than a single event
56. Have you ever received any training in investigations, if so, when and what
57. Have you ever received any training in sexual abuse of children, if so, when and what
58. In 1989, what was your understanding of a sexual predator regarding having more than
one victim or abusing the victim more than once.
59. How long have you known Margie GOLDSCHMIDT
60. Do you have any independent knowledge of how many children Margie and Neil
GOLDSCHMIDT have
61. If so, when did you meet their children
62. If so, describe them
63. Describe your relationship with the GOLDSCHMIDT children
65. When did you first meet him
67. Do you recall attending a 1994 holiday party at Margies
68. If so, what was your role at this party, i.e. attendee, host, etc
69. Do you recall who else was there?

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70. Do you recall KULONGOSKI and his wife being there
71. Do you recall LEONHARDT and Christy being there
72. Do you recall them arriving together
73. Do you recall a discussion between yourself and LEONHARDT regarding any
misconduct of GOLDSCHMIDT?
74. If so, describe specifically what the discussion included
75. At the party, what did you tell LEONHARDT about your knowledge of
GOLDSCHMIDTs misconduct
76. Did you tell LEONHARDT that GOLDSCHMIDTs crime was going to be exposed in
the media soon?
77. How did you obtain this knowledge
78. What did you tell LEONHARDT about GOLDSCHMIDTs wifes knowledge of his
misconduct?
79. What did you expect to hit the media regarding GOLDSCHMIDTs misconduct and
its consequences?
80. How did you obtain this knowledge?
81. Describe your knowledge of a lawsuit between GOLDSCHMIDTs victim and
GOLDSCHMIDT
82. How did you obtain this knowledge
83. Describe your knowledge of the GOLDSCHMIDTs sealed divorce records being
reopened.
84. Did you see LEONHARDT and KULONGOSKI sitting on the floor at the party
talking
85. How did you obtain this knowledge?
86. Describe your knowledge of the purpose of the lawsuit, why the lawsuit
87. Have you ever met Pam Dunham
89. Describe your relationship with Pam Dunham
90. Where did Pam Dunham work, was it in state government?
91. If so, did she work in the GOLDSCHMIDTs administration
93. Do you recall assisting KULONGOSKI in his election for Governor
94. If so, what was your involvement
95. If so, do you recall a time in which you promoted or appeared for his election in
uniform
96. If so, do you recall the IACP identifying concerns with your actions?
97. If so, what did the IACP tell you?
98. At what point did you and Margie become involved in a romantic relationship
99. Did you continue to serve in GOLDSCHMIDT administration, on behalf of OSP after
your relationship with Margie began?
100. If so, for how long
101. Did you engage in a competitive promotion process from Sergeant to Lieutenant
102. Was there a promotional list
103. If so, where did you ultimately score, of how many candidates
104. Did you have any discussions with the GOLDSCHMIDT administration about
individuals in your position being promoted as a result of serving in that position?

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105. If so, who did you discuss this with
106. What did you discuss
107. Lt. RADER, racial comments, Oreo, in presence of New Orleans half black and
half white deputy.
108. Was this investigated?
109. Investigated internally or externally? SOP 6.07 required the matter to be
investigated by an outside investigator, and this was the recommendation of the IA
unit, why was it investigated internally by GRAHAM
110. What were the results, discipline, diversity training,
111. Who was the final decision maker?
112. Was the victim notified?
113. Female sergeant reprimanded for misuse of leave, union grieved, won.
114. Was this investigated
115. Investigated internally or externally
116. What were the results, discipline, diversity training,
117. Who was the final decision maker?
118. Relationship between Lt. LONG and this female Sgt;
119. Was the relationship a part of the grievance?
120. Was this Sergeant in Lt. LONG chain of command.
121. Emails to female subordinates
122. Have you ever emailed any female subordinate within your agency in which the
email contained other than work-related content
123. If so, whom did you email
124. How many times
125. What was the content of the email
126. What is your agency policy on sending personal emails?
127. Was your emails consistent with agency policy
128. Have you ever received information about any complaint by a female employee of
MCSO in which one or more of your emails were at issue
129. If so, who was the complainant
130. If not first hand, and another person was complaining on the females behalf, what
was their complaint
131. Was this resolved
132. How was this resolved
133. Do you have any knowledge of your Chief Deputy communicating with MCSO HR
Director regarding this incident
134. Do you have any knowledge of the HR director discussing the event with the female
who received your emails.
135. If so, who was the HR Director
136. DO you have any knowledge of what the HR Director may have communicated with
the female?
137. Are you aware of any individual communicating to OTT that she was not to tell or
she will be fired.
138. Are you familiar with Chaplain Ed STELLE
139. If so, how long have you known him

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141. Who has the responsibility for oversight over Chaplain STELLE
142. Who has the responsibility of Chaplain STELLEs employment contract
143. Are you aware of a financial change in this contract
144. If so, do you know why the change was made
145. Who made the decision to make the financial change
146. What was the basis for the financial change
147. Are you familiar with any female volunteer chaplain who has worked at the
Inverness Jail
148. If so, what is her/their name(s)
149. Have you ever met her and if so when
150. Describe your relationship with her
151. Determine timeline of possible relationship between GIUSTOs connection to
volunteer and contract change
152. What Chief Deputy resigned during the JEDDELOH incident, and why?
153. Describe the disappearing file on the JEDDELOH license issue, reappear?
154. Describe how the documents may have been, or were, altered documents sent to DOJ
on JEDDELOH file?
155. SOP against photocopying personal info?
156. Are you aware of insurance documents belonging to JEDDELOH that were found on
or near the photocopy machine; who found them, what were they
157. Do you recall who the Gresham City Council were when you served as the Chief of
Police for the Gresham Police Department
158. Specifically, did you have, or develop, a relationship with a female councilwoman?
159. If so, who was she
161. As you understand it, what were her duties and responsibilities
162. Do you believe at any time that you benefited from your personal relationship?
163. Were there any decisions that this councilwoman made that had a positive or
negative impact on you?

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28. MCSO Sheriff Bernard GIUSTO Interview Summary

On October 1, 2007, PARSONS and KING interviewed Bernard GIUSTO at his place of
employment. Accompanying him was Lt. Bruce McAIN.
GIUSTO was advised that LEONHARDT had been interviewed and had taken and passed a
polygraph test attesting to an affidavit he had signed.
After GIUSTO provided his law enforcement background, PARSONS asked him what
experience he had as an investigator. GIUSTO stated he had not been a detective but had
worked with them as a public information officer (PIO).451 When asked if GIUSTO had any
investigative training, he stated none other than his basic police training and his work
experience.452 When asked if GIUSTO had ever handled internal investigations, he stated he had
not; but did oversee them from a very long distance.453 GIUSTO did state that he reviewed
internal investigations.
When asked if GIUSTO was aware that often a suspect will either omit information, minimize
conduct, diminish their involvement or created an inaccurate picture by misrepresentation,
GIUSTO stated yes, its called lying . . .omissions, co-missions.454 When asked if GIUSTO
was aware officers also engage in this during internal investigations, GIUSTO stated he was.
PARSONS asked GIUSTO how he would handle those situations and he stated it depended on
the seriousness of the situation and the degree. When asked if he ever meted out discipline for
an officers failure to provide accurate information, GIUSTO stated yes, but it depended on the
individual situation.455
When asked if GIUSTO had training in the field of sex abuse he stated no. GIUSTO clarified
that he had not been to a class on investigation of sex abuse but had been to training which
included new legislation on changing the sex abuse law. GIUSTO stated he had a general sense
through his training with the State Police.456 This training included his six-week academy,
general law covering the statutes and experience over time. When asked if GIUSTO had ever
been involved in an investigation himself or with others, in which a child sexual predator has
been investigated and there was only one encounter with one victim, GIUSTO stated no. When
asked if these predators had just one victim or only one incident, GIUSTO stated the vast
majority [have]. . . multiple victims or multiple times with one victim. GIUSTO stated he had no
training nor has he done independent research on child sexual predators.457
When asked how long GIUSTO had known LEONHARDT, he stated since 1987. GIUSTO
stated that he met him when LEONHARDT was the speechwriter for GOLDSCHMIDT.
451
Ex A3d, p 3
Ex A3d, p 4
453
Ex A3d, p 5
454
Ex A3d, p 6
455
Ex A3d, p 7
456
Ex A3d, p 8
457
Ex A3d, p 10
452

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GIUSTO stated he had met Christy, LEONHARDTs wife, sometime after meeting Fred.458
When asked if the LEONHARDTS have any children or if he had met them, GIUSTO stated he
had seen their kids, but not for 12 years. When asked where he met the LEONHARDTS
children, he could not recall if he met them at the LEONHARDTS home or at the office.459
When asked how often GIUSTO was at the LEONHARDTs residence, GIUSTO stated
seldom and recalled only one time; a social occasion.460
When asked to describe his relationship with LEONHARDT, GIUSTO stated he saw
LEONAHRDT primarily in the context of his job on the governors staff, they would have
breakfast together once in awhile, and that after he left the office in 1989 he saw him rarely.
When asked if GIUSTO socialized with LEONHARDT after he left the office, GIUSTO stated,
once in awhile and recalled a couple times for dinner type things. GIUSTO recalled seeing
the LEONHARDTS at a Christmas party at Margies home.461 GIUSTO did not recall if the
KULONGOSKIS were also at that particular party. GIUSTO did recall one time he had dinner
with KULONGOSKI and his wife, and thought it was prior to the time KULONGOSKI was the
Governor, but could not recall if the LEONHARDTS were a part of that party, but it might have
been myself and Margie, the Leonhardts, and and the KULONGOSKIS.462
When asked the last time he spoke with Fred LEONHARDT, GIUSTO thought it was during the
timeframe of the Christmas party. When asked if GIUSTO recalled LEONHARDT being at
KULONGOSKIs inaugural event, GIUSTO could not recall.463
When asked if GIUSTO recalled offering to give LEONHARDT a ride from Portland to Salem
and subsequently stopping for breakfast, GIUSTO stated, I think I remember the ride.464
When asked if GIUSTO picked LEONHARDT up on more than one occasion, GIUSTO stated,
I couldve. When asked if LEONHARDT lives in close proximity to GIUSTO, he stated,
no. GIUSTO stated he was living in Gresham and affirmed that LEONHARDT was living in
northeast Portland. GIUSTO denied that it would be considerably out of the way and stated I
dont remember ever . . .picking him up at a house . . . .going to his house and picking him
up.465
When asked how often GIUSTO had breakfast with LEONHARDT, he stated he did not know
about breakfast but shared several meals. GIUSTO stated that he socialized with
LEONHARDT very little.466
When asked if GIUSTO recalled a conversation between him and LEONHARDT involving a
discussion about GOLDSCHMIDT engaging in misconduct with a minor female, GIUSTO
458
Ex A3d, p 11
Ex A3d, p 12
460
Ex A3d, p 13
461
Ex A3d, p 14
462
Ex A3d, p 15
463
Ex A3d, p 16
464
Ex A3d, p 17
465
Ex A3d, p 18
466
Ex A3d, p 19
459

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stated, not . . .not as a single topic. GIUSTO stated that the issue of the female was along
with a 1000 other rumors . . .rumors abounded. . .the fact that I took any . . . energy to talk to
Fred about a specific topic . . .about any topic relative to this or anything else is frankly just in
his imagination.467 GIUSTO went on to say, I didnt say that I never heard about this issue, I
said I dont have any specific knowledge.
When PARSONS stated that LEONHARDT had said he had learned the information from
GIUSTO, that LEONHARDT was surprised about the information and that GIUSTO had shared
particulars about the victim with him, to include the name of the victim, GIUSTO stated that
LEONHARDT reads about it in the newspaper and then comes forward. GIUSTO
characterized LEONHARDT as vindictive. GIUSTO stated the first time he knew about any
victim was in the 1990s during a conversation with Margie GOLDSCHMIDT and there was a
lawsuit. GIUSTO pointed out that no crime has ever been charged, filed or a report written.468
GIUSTO stated that LEONHARDT was alleging things that were of concern only if they were a
current crime. . . or . . if behavior was to show itself again in that individual . . .as a trained
police officer -- . . .my job is not to delve into the noncriminal aspects of things once they are
past469 . . .many things turn into the civil side regardless of the criminal liability of it even when
it was a crime. Let alone when its 13, 14, 15 16 years after the statute has run.
PARSONS asked GIUSTO if there were other rumors about GOLDSCHMIDT having a
relationship with minor children. GIUSTO stated, No, there werent any other ones. . . if there
had been any indication that was going on currently or was of current concern or was even
potentially an issue around that, you can . . .rest assured that it would have been pushed where it
needed to be pushed by me.470
GIUSTO stated he has never had a conversation with GOLDSCHMIDT about the matter. When
asked if GIUSTO had a conversation with LEONAHRDT about GOLDSCHMIDT having sex
with a minor, GIUSTO stated thats probably yes, but in. . . generalities. GIUSTO stated he
hasnt spoken with LEONHARDT since 1994, when he first learned about it from Margie.471
When asked if GIUSTO had a conversation with anyone else about GOLDSCHMDIT having a
relationship with a minor girl, GIUSTO stated he had conversations but not that he initiated the
conversations. When asked who he had conversations with, GIUSTO stated with Debbie
KENNEDY he may have mentioned that but that he did not initiate [the conversation]. 472
GIUSTO reiterated that he does not pursue things that are non-criminal unless the behavior
looks to be continuing.473
When asked what GIUSTO knew about the rumor when he was security for GOLDSCHMIDT,
GIUSTO stated he didnt know anything, that he heard in a rumor fashion was the female
467
Ex A3d, p 20
Ex A3d, p 22
469
Ex A3d, p 23
470
Ex A3d, p 24
471
Ex A3d, p 25
472
Ex A3d, p 26
473
Ex A3d, p 27
468

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there might have been a problem. GIUSTO stated his job was not to be close to the governor .
. my job is to be an arms length away. . . .the idea I heard anything directly from anybody that
had any direct information is false.474
When asked if GIUSTO heard the victim was a female, as opposed to a male, GISTUO stated it
was a female. When asked if he had heard the victim was underage, GIUSTO stated, yes, I
heard it was underage.475 GIUSTO did not recall who he had heard this information from.
GIUSTO stated that this rumor was well known.
When asked if GIUSTO heard at any point that the victims mother was associated with
GOLDSCHMIDT, GIUSTO stated it was much later in time.476 When asked if GIUSTO had
also heard of the timeframe of when GOLDSCHMIDT had engaged in the crime, GIUSTO
stated he didnt know, when the civil suit was filed he found that it was back in the 70s when
[GOLDSCHMIDT] was in the mayors office.477
GIUSTO stated that during a conversation with Margie, he learned the victims mother worked
on GOLDSCHMIDTs mayoral campaign.478
When asked if GIUSTO developed an intimate relationship with Debby KENNEDY, GIUSTO
affirmed he had. When asked if GIUSTO recalled telling KENNEDY that GOLDSCHMIDT
had a sexual encounter with an underage female, GIUSTO stated he did not recall that specific
conversation, but he couldve mentioned it, GIUSTO did not recall initiating the conversation.
When asked when GIUSTO had last spoken with KENNEDY, GIUSTO stated the last time
KENNEDY had called him for lunch, 3-5 years ago, or right after he was elected.479 When
asked if GIUSTO recalled a time that he went to KENNEDYs home and told her that
GOLDSCHMIDT had sex with an underage girl, GIUSTO stated he recalled going to her home
but did not recall any specific conversation about it. When asked whether the last time
GIUSTO went to KENNEDYs home he told her that GOLDSCHMIDT had sex with an
underage girl and that he was having an affair with Margie GOLDSCHMIDT, GIUSTO stated he
did go to KENNEDYs house but the progression of rationale about why . . .one led to the other
is not neither my style nor do I even recall that conversation.480
When asked specifically if GIUSTO recalled a time when he went to KENNEDYs house and
talked with her about the GOLDSCHMIDT crime, GIUSTO stated there was no crime and asked
which crime.481 GIUSTO then asked if it was the one that the statute ran on and KING
confirmed the crime of having sex with an underage female. PARSONS clarified that whether
prosecutable or non-prosecutable, it is still a crime to have sex with a 13-year old.482 GIUSTO
474
Ex A3d, p 28
Ex A3d, p 28
476
Ex A3d, p 29
477
Ex A3d, p 31
478
Ex A3d, p 32
479
Ex A3d, p 33
480
Ex A3d, p 37
481
Ex A3d, p 37, line 20
482
Ex A3d, p 38
475

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stated he did not recall [the conversation with KENNEDY] and was not saying that it didnt
occur. When asked if GIUSTO recalled that his personal relationship with KENNEDY ended at
that time, GIUSTO stated, I guess . . .we couldve ended it then . . .I dont remember that it had
anything to do with that conversation or any other conversation . . it had nothing to do with any
conversation I had with her.483
When asked about the circumstances surrounding GIUSTOs promotion from sergeant to
lieutenant, and if he engaged in a competitive promotion process, GIUSTO stated he had not.
When asked how the promotion occurred, GIUSTO stated that since Governor HATFIELD got
shot in the 50s, every driver had been a lieutenant in the State Police. GIUSTO stated that when
he was assigned to GOLDSCHMIDTs security, he went to the superintendent and told him he
thought he was entitled to be a lieutenant like everybody else . . .he made me a lieutenant.
GIUSTO identified the superintendent as Emil Brandaw. GIUSTO did not recall if he spoke
with anyone in his chain of command or if he went straight to the superintendent. GIUSTO
offered that GOLDSCHMIDT had no idea that he was pursuing the rank, that GOLDSCHMIDT
did not care and that he did not have a conversation with him.484
When asked if GIUSTO recalled assisting KULONGOSKI in his governor campaign, GIUSTO
stated that he had.485 When asked if someone from IACP had contacted him with concerns
about his involvement, GIUSTO stated not to his knowledge and he had not been contacted by
anyone.486
When asked about Lieutenant RADER using a term Oreo GIUSTO did recall that incident.
When asked if the incident was investigated internally or externally, GISUTO stated that when
the complaint came to them, there was a long conversation about the proper method to handle it,
given the context of the complaint and the motivation behind the complaint which was not just
the deputy, but the union. GIUSTO stated it was his direction that the incident be directed down
to the chief [GRAHAM] to be discussed with both employees. When referred to the SOP 6.07
and asked why that policy had not been followed, GIUSTO stated that he considered the intent of
the policy and that because this incident was not a chronic issue relative to what the policy is
meant to address; a hostile work environment, he believed it was best addressed both internally
and directly face to face with employees. GIUSTO stated it was within his purview to make
such a decision.487
When asked if there was any discipline or required training as a result of the investigation,
GIUSTO stated there were significant conversations with both employees; that they met face to
face and RADER apologized and they moved on.488
When asked about the Dianna OLSEN issue, GIUSTO recalled that there was an investigation
conducted externally, a report was compiled, and an executive summary was completed.489
483
Ex A3d, p 38
Ex A3d, p 41
485
Ex A3d, p 42
486
Ex A3d, p 44
487
Ex A3d. p 47
488
Ex A3d, p 48
489
Ex A3d, p 49
484

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GIUSTO stated the investigation identified a chronic attitude and issues with both OLSEN and
RADER regarding personality conflicts. When asked what the relationship between RADER
and OLSEN was, GIUSTO stated RADER was OLSENs supervisor.490 When asked if the
relationship was a part of the grievance, GIUSTO affirmed it was.
When asked if GIUSTO had sent any non-work related, personal emails to female subordinates
within his agency, GIUSTO stated it was possible.491 When asked if GIUSTO sent emails that
would be strictly of a personal nature having nothing to do with any work related business,
GIUSTO affirmed he had. When asked if GIUSTO had a agency policy regarding emails for
personal use, GIUSTO stated they did have a policy and they could send such emails.492
When asked if GIUSTO had received information about a complaint by a female employee who
worked in SIU, GIUSTO stated he had but did not believe it was a complaint. GIUSTO stated he
had received information that a female had been saying there was something that she was not
sure of and that she was approached by the human resources manager and asked about it. When
asked what the nature of the issue was, GIUSTO stated that he did not believe the female ever
defined any issues and he does not know what the female was concerned about.493 GIUSTO
stated the female would come to his office to talk with him on a regular basis. GIUSTO stated
that at one point they were talking about wine and GIUSTO brought the female a couple of
bottles of wine. GIUSTO stated that the female sent him an email thanking him for the wine.494
GIUSTO stated that he gives other employees gifts, both males and females.
When asked if there was a conversation between the female and GIUSTO about going to the
beach, GIUSTO stated that they discussed her beach house and him also going to the beach to his
place. GIUSTO did recall calling the female employee when he and his female friend were
driving to the beach to stop by on his way, but stated he left a voicemail, that they never did
connect and that was the end of that.495 When asked if GIUSTO called the females personal cell
phone, GIUSTO stated he did. When asked if that was a telephone number he would normally
have, GIUSTO stated that the female had given him her cell phone number. GIUSTO confirmed
that the female employee was Deirdre McGILL and that it was Sean CHRISTIAN who had
contacted him.496 GIUSTO stated that other than the phone call he has never contacted McGILL
outside of the workplace. When asked what CHRISTIAN told him, GIUSTO stated that
CHRISTIAN told him he should stay away from McGILL. When asked if GRAHAM was
present, GIUSTO affirmed he was. GIUSTO stated that he had no knowledge what occurred
after that because GRAHAM handled it and GIUSTO did not direct any investigation or follow
up on the issue.497 GIUSTO stated he had no knowledge of what OTT communicated to
McGILL. When asked if GIUSTO was aware of any individual communicating with McGILL
that she was not to tell anyone about the issue or she would be fired, GIUSTO stated he was not.
490
Ex A3d, p 50
Ex A3d, p 51
492
Ex A3d, p 52
493
Ex A3d, p 53
494
Ex A3d, p 54
495
Ex A3d, p 55
496
Ex A3d, p 56
497
Ex A3d, p 57
491

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When asked if GIUSTO was familiar with Chaplain Ed STELLE, he stated he was and had
known him for 20 years. GIUSTO stated he knew STELLE had been involved in law
enforcement for at least fifty years. GIUSTO stated that he has interacted with STELLE over the
years and when he became the sheriff, STELLE was the chaplain for both corrections and law
enforcement.498
GIUSTO stated that he identified some improvements that were needed on the corrections side
regarding backgrounding volunteers and training programs. GIUSTO stated that he asked
STELLE go to the law enforcement side, but still be available if employees needed him, but that
GIUSTO did not want STELLE responsible for the jails any longer. GIUSTO stated that he
really wanted STELLE to focus on the peer support function. GIUSTO stated that STELLEs
job pretty much remains the same with the exception of a reduction in STELLEs salary and
hours due to a budget issue. STELLE was also put on contract as opposed to a full-time
employee and that they came to an agreement. GIUSTO stated that STELLEs salary was cut in
half but there was also a retirement program set up for STELLE which he did not previously
have.499
MCCAIN clarified that STELLE historically had been the chaplain for employees and that they
have a separate program for inmates that STELLE was historically not a part of; he was the
employee chaplain as opposed to religious services for inmates.
When asked who took over the jail function, GIUSTO stated that he has about 75 volunteer
chaplains and two full-time paid chaplains and that GIUSTOs assistant, Catherine MOYER,
took the program over.500 GIUSTO identified the two full time chaplains as Scott DUNCAN and
Lewis KYLE; both inmate oriented chaplains.501
When asked if GIUSTO knew any of the female chaplains personally, GIUSTO stated he did.
GIUSTO identified Marilyn LEE, Alice TATE and another woman named Betty. When asked if
he had any friendships with the female chaplains, GIUSTO identified TATE as his next door
neighbor and stated that she had obtained her position through Ed STELLE, not through him.502
When asked if any female was brought in to replace STELLEs function or to cause him to take a
reduction in pay, GIUSTO stated no.
When asked if GRAHAM retired during the JEDDELOH incident, GIUSTO stated GRAHAM
did not retire but he left to go to work for Gresham. When asked why GRAHAM left, GIUSTO
stated that GRAHAM told him he wanted to return to police work.503 When asked about
GRAHAM taking a pay cut, GIUSTO stated that his observations were that GRAHAM grew up
getting promoted and when GRAHAM took the chief deputys job he wasnt really done being a
lieutenant.504 GIUSTO stated that GRAHAM found parts of the position difficult and that it was
498
Ex A3d, p 60
Ex A3d, p 62
500
Ex A3d, p 63
501
Ex A3d, p 64
502
Ex A3d, p 65
503
Ex A3d, p 66
504
Ex A3d, p 67
499

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not operationally oriented enough for him at the chief deputy level; that GRAHAM really wanted
to return to working a [patrol] car.505
When asked about the allegation that the JEDDELOH file had been altered from the time it was
originally on the desk for approval until it came back later with a do not issue, GIUSTO stated
that JEDDELOH told GIUSTO he wanted a concealed handgun permit and GIUSTO told him
they could assist. GIUSTO stated that he then told GRAHAM to drop off [the application] and
give JEDDELOH a little instruction on how to do it. GIUSTO stated that the staff thinks
because the sheriff asks for something, and because the chief deputy was doing something with
it, that they had to speed it up or do something faster with it, although that was not his intent.506
GIUSTO stated that the file came to him and he looked at it briefly. GIUSTO stated he did not
look at it as carefully as he was supposed to look at it, that he signed the document to give him
the handgun permit and it went back to GRAHAM. GIUSTO stated that GRAHAM then came
to JEDDELOH and asked if he had looked at the application and told GIUSTO that he was not
comfortable issuing the permit. GIUSTO stated that he then asked GRAHAM about it and at
that point GRAHAM described the diversion which requires, by sheriffs office rule, that one
must be off diversion to get a permit. GIUSTO stated that GRAHAM asked GIUSTO if he had
seen the domestic violence information and he told GRAHAM he had not. GIUSTO stated he
reviewed JEDDELOHs application again and believes he put a sticky note on it indicating not
to issue or hold the application until they heard from him. GIUSTO asserted that no documents
I ever signed were changed . . . removed. . . altered. . . shredded . . . or anything else in that
file.507 The only thing GIUSTO recalled was a sticky note indicating he wanted the application
held.
MCCAIN added that as a result of an Oregonian public records request, he photocopied the file,
including a sticky note that indicated, Suspend until further notice and it was initialed by
Kathy WALLIKER.508 MCCAIN did not see an approval sticky note but indicated that
ELLIOTT had a copy of it. GIUSTO stated that the sticky note did not matter because he
recalled [initially] signing the application.509
GIUSTO stated that the application process stopped between the time that GRAHAM asked him
to look at the file again and when records had the file and called JEDDELOH. When asked if
GIUSTO recalled GRAHAM coming to him prior to anyone approving or disapproving the file
and telling him that he would not approve it because of a DV problem, and stating that you could
approve it if you wanted to, but that GRAHAM was not going to, GIUSTO stated he did not
remember that.510 GIUSTO stated he did not recall it in that order at all, that he was not saying
that it couldnt have been but that is not the way he remembered it. GIUSTO stated that
GRAHAM may not have looked at the application to see that GIUSTO had already signed it, and
he was not sure in what order it happened.511
505
Ex A3d, p 68
Ex A3d, p 70
507
Ex A3d, p 71
508
Ex A3d, p 72
509
Ex A3d, p 73
510
Ex A3d, p 74
511
Ex A3d, p 75
506

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PARSONS told GIUSTO that GRAHAM was contacted by staff about the DUII and the DV and
it was at that point that GRAHAM stated he had gone to GIUSTOs office and told him about the
criminal activity and that GIUSTO had approved the application after GRAHAM had spoken to
him. GIUSTO recalled the conversation and stated that [GRAHAM] could have, that he should
not have signed the application, that he should have taken a closer look at it or paid closer
attention to GRAHAM. GIUSTO then stated that the application was not complete because
JEDDELOH had not paid his $25 nor had he been fingerprinted; the application was never
issued.512
KING asked GIUSTO how may applications he had personally signed and GIUSTO thought the
JEDDELOH application was the only one. When asked if an application had come to him for
signature would that have been a red flag, GISUTO stated no, because once in awhile the staff
gets little things backwards . . .513 When asked if GIUSTO helped others getting their licenses,
GIUSTO stated he had not helped out, he just gave one instruction to deliver a permit. When
asked in those cases when the staff received the same message, if they brought it back to
GIUSTO, he stated that because GRAHAM had carried the application back, it may have sent a
different message to people. GIUSTO then stated that as sheriff he can issue a handgun license
to anybody he wants to, outside of mental illness.514, 515
When KING asked if GRAHAM was correct if he were to have told investigators that when he
reviewed JEDDELOHs file and saw the DV and the DUII that he came to GIUSTO and
provided a verbal rundown of the criminal history and then asked that GIUSTO review the
criminal history after GRAHAM had specifically identified the DUII diversion and a DV
incident, GIUSTO stated it would be partly incorrect; that GRAHAM did state you might want
to take a look at this.516 When asked if GRAHAM had told GIUSTO that there was a DUII
diversion and a DV, GIUSTO stated no, then stated GRAHAM said there was a DUII diversion,
but that he did not remember when he found out that MCSO does not issue on DUII
diversions.517 When asked if GRAHAM were to have told investigators that in his very first
contact with GIUSTO after getting the file from records he told GIUSTO specifically that
[JEDDELOH] had a DUII diversion and a DV incident, if GRAHAM was incorrect, GIUSTO
stated he did not remember, that he remembered GRAHAM saying, You might want to take a
closer look at this. When asked if GIUSTO recalled GRAHAM telling him that he was not
going to sign the application and that if GIUSTO wanted it done he would have to sign it
himself, GIUSTO did not recall the conversation in those terms, but stated he could have. 518
Ten minute break.
Back on the record, GIUSTO was asked about his time as the Chief of Police at Gresham Police
Department and whether he knew Gresham city council women. GIUSTO stated he did and
512
Ex A3d, p 76
Ex A3d, p 77
514
Ex A3d, p 79
515
Ex A6l, Concealed handgun licenses statutory authority; law differs from GIUSTOs assertion
516
Ex A61, p 80
517
Ex A3d, p 80
518
Ex A3d, p 81
513

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named several. GIUSTO stated that he spoke with all of them. When asked if any of them and
he had the type of relationship that he felt he benefited from as the chief because of his
relationship, GIUSTO stated no. When asked if he felt any of them more of a friend, or if they
were all equal, GIUSTO stated they were fairly identical; although he had known THOMPSON
for a longer period of time.519 When asked about McINTIRE, GIUSTO did not think that she
was a councilwoman when he was the Chief.
When asked if GIUSTO recalled a party that was held at Margie GOLDSCHMIDTs home in
which the KULONGOSKIS and the LEONHARDTS were present and if he recalled talking to
LEONHARDT about some breaking news about the GOLDSCHMIDT scandal, GIUSTO did not
recall that conversation.520 GIUSTO recalled more than one party where Fred LEONHARDT
was present, and one with Ted and Mary, but did not recall the conversation with
LEONHARDT.521 When asked about a conversation prior to when anything had come out about
GOLDSCHMIDT, GIUSTO stated he did not recall. When asked if during this time GIUSTO
recalled unsealing of papers relating to Margie GOLDSCHMIDT, GIUSTO stated the answer is
partly yes. GIUSTO stated that it was likely through Margie GOLDSCHMIDT and a
conversation they had about a claim about money and a civil settlement. GIUSTO recalled that
this occurred in 93 or94. GISUTO stated that it was a civil settlement about this alleged issue.
. .never a crime522, never constituted as anything other than . . .a civil allegation. GIUSTO
stated that that part was correct, but the part about him telling LEONAHRDT it was going to
break in the news was not correct.523 GIUSTO stated he was aware of the settlement from his
conversation with Margie, but did not know how much and that Margie GOLDSCHMIDT had to
unseal her divorce papers.524
When asked if GIUSTO shared this information with LEONAHRDT, GIUSTO stated he did not
share that information with LEONHARDT. When asked if LEONHARDT ever spoke with
GIUSTO after the party about why the news had not broken, GIUSTO stated he did not. When
asked if GIUSTO shared with LEONHARDT at the party about the unsealing of the divorce
papers, GIUSTO stated I dont know whether I did or not.525
When asked at the point that GIUSTO learned from Margie that they were unsealing her divorce
papers, and that there was to be a settlement, who he told, GIUSTO stated he did not recall
talking to anybody specifically about it as a purpose for conversation. GIUSTO stated that he
did not recall and characterized it as something that was one of many things going on in life
thats noncriminal. When PARSONS identified that it was fairly significant because of the
politicians stature and information that would be incredibly damaging to GOLDSCHMIDTs
reputation, GIUSTO stated that it was the same information that Senator Vicky WALKER had in
a packet and chose not to share with the governor [KULONGOSKI] because she didnt think it
was her responsibility prior to the Higher Ed Board appointment. GIUSTO stated WALKER
had alot more information and specifics but she chose not to share it. GIUSTO stated he did not
519
Ex A3d, p 84
Ex A3d, p 86
521
Ex A3d, p 87
522
Ex A6k Criminal conduct, as affected by the statute of limitations; law differs from GIUSTOs assertion
523
Ex A3d, p 89
524
Ex A3d, p 90
525
Ex A3d, p 92
520

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have independent recollection of a place or conversation. When asked if GIUSTO could have
told LEONHARDT, GIUSTO stated not in the method that LEONHARDT talked about and
GIUSTO stated that if he had given this information to LEONHARDT, why he didnt check
back to see what happened. 526
When asked if GIUSTO ever shared the information with KULONGOSKI, GIUSTO stated he
had not. When asked if GIUSTO ever recalled seeing KULONGOSKI and LEONHARDT
sitting together behind a sofa in conversation, GIUSTO stated he did not recall and that he had
no independent knowledge.527
When asked if GIUSTO went to Seattle with JEDDELOHs wife while JEDDELOH was in
rehab at the Betty Ford Clinic, GIUSTO stated, Yes.528 When asked if it was for the weekend,
GIUSTO stated it was. When asked if Mrs. JEDDELOHs children accompanied them,
GIUSTO stated they did not. When asked if Jim JEDDELOH had been served with the divorce
papers yet, GIUSTO stated he did not know; that he did not serve him. When asked if GIUSTO
and Mrs. JEDDELOH took any other out-of-town vacations during the period of time that Mrs.
JEDDELOHs husband was at the Betty Ford Clinic, GIUISTO stated he did not remember any.
529
When asked if GIUSTO had any personal papers of Mrs. JEDDELOHs that he copied using a
county copy machine, or fax, GIUSTO stated no.530
When advised that LEONHARDT provided an affidavit and took a polygraph and that
investigators were offering GIUSTO the same opportunity, GIUSTO declined.531
GIUSTO, MCCAIN, KING and PARSONS discussed the next process steps and administrative
rules. GIUSTO also addressed why he had asked Todd SHANKS to run KIM through LEDS.532
526
Ex A3d, p 95
Ex A3d, p 96
528
Ex A3d, p 97
529
Ex A3d, p 98
530
Ex A3d, p 99-100
531
Ex A3d, p 100-101
532
Ex A3d, p 101-106
527

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29. KIM GIUSTO Interview Questions

Background
KIM GIUSTO was married to Bernard GIUSTO during the time that he worked security for
GOLDSCHMIDT. The focus of questions would be on whether GIUSTO told her about
GOLDSCHMIDTs crime, if so, when and what did he tell her.
1.
2.
3.
4.
How long have you known about GOLDSCHMIDTs crime

Whom did you learn about this crime from
When did you learn about the crime
What specifically did you learn
30. KIM GIUSTO Interview Summary

On October 4, 2007, KIM GIUSTO called KING, responding to a telephone message left earlier
in the day by PARSONS. When advised that a focus of the investigation was on what
knowledge Bernard GIUSTO had about the GOLDSCHMIDT crime, and when he had gained
the knowledge, and if Bernard GIUSTO had had any discussions with her about these matters,
KIM GIUSTO responded, Absolutely not. KIM GIUSTO stated that Bernard GIUSTO was
gone 18 hours a day and they basically talked about his sick mom and their son. KIM GIUSTO
added that she thought Bernard GIUSTO had a lot of integrity.533
533
Ex A 65c, p 2-3

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31. Tom GIUSTO Interview Questions

1. How long have you known about GOLDSCHMIDTs crime
2. Whom did you learn about this crime from
3. When did you learn about the crime
4. What specifically did you learn
5. When is the first time you had contact with Fred LEONHARDT
6. Did you contact him or did he contact you?
7. Was the contact in person or by telephone
8. How did you obtain his telephone number
9. What did you and he discuss, topics, people, events
10. How long was your telephone conversation
11. Who ended the telephone conversation
12. Have you had any subsequent contact with LEONHARDT since this phone call
13. Have you had any contact with any individual from the media regarding Neil
GOLDSCHMIDT or your brother Bernie
14. When did you have this contact
15. Was it in person or on the telephone
16. With whom did you have the contact
17. What did you discuss, topics, people, events
18. More than one media person/source?

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32. Tom GIUSTO Interview Summary #1

On June 21, 2007, PARSONS spoke with Tom GIUSTO over the telephone. In response
to PARSONS asking to meet, GIUSTO stated that he was not ready to meet. PARSONS
asked GIUSTO to call back and said if he talked to investigators, he would not have to
answer any questions he did not want to. GIUSTO thanked PARSONS for her
professionalism and the conversation ended.
33. Tom GIUSTO Interview Summary #2
On October 9, 2007, PARSONS returned a telephone call to Tom GIUSTO who stated he had
contacted BUDNICK for the investigators telephone number. When GIUSTO asked PARSONS
how he could help her, referring to their prior conversation of June 21, 2007, PARSONS stated
there were a couple of areas of interest; whether Bernard GIUSTO talked to him about
GOLDSCHMIDTs crime and his conversation with LEONHARDT.
GIUSTO stated that he had called LEONAHRDT because he was upset with his brother for a
number of reasons.534 GIUSTO then asked to talk off the record and PARSONS advised him
that it would ultimately be public information.535 GIUSTO sought clarification of the difference
between talking to a reporter, who allowed off the record conversations and a state
investigator. GIUSTO stated he was the only information and Im the only source, and was
trying to decide at which point . . .I have to be penalized to . . . validate your assistance.
GIUSTO stated, its nothing famous about . . . turning on your brother. 536 When PARSONS
asked what GIUSTOs concerns were (about talking to her) GIUSTO stated The reflection on
me in the community and my business . . .negative, that I ratted him out. PARSONS asked
GIUSTO if there were things he wanted on the record, such as his conversation with
LEONHARDT. GIUSTO stated that after the article came out, Fred wouldnt call me. He
wouldnt return my calls. When asked why, GIUSTO stated, Because it wasnt true, and
went on to say that he had called LEONHARDT to find out what his experience was with
coming out.537 GIUSTO stated that once he found that it (talking about his recollections)
ruined his life GIUSTO didnt do anything. GIUSTO stated that LEONHARDT thought
GIUSTO was going to collaborate with him, but GIUSTO did not want to ruin his life as
LEONHARDT had and that LEONHARDT was paying the price.538 GIUSTO asked
PARSONS whether she had spoken with a number of other individuals, including the media.539
PARSONS clarified that investigators were not focused on the morality of an affair with Margie
GOLDSCHMIDT, but on being untruthful.540 GIUSTO told PARSONS she should speak with
Les ZAITZ regarding statements that Bernard GIUSTO made on two different occasions that
were not true.541 When PARSONS asked GIUSTO if he had personal knowledge of whether
534
Ex A17g, p 3
Ex A17g, p 4
536
Ex A17g, p 7
537
Ex A17g, p 11
538
Ex A17g, p 12
539
Ex A17g, p 15
540
Ex A17g, p 16
541
Ex A17g, p 18
535

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Bernard GIUSTO was having an affair with Margie GOLDSCHMIDT during the time he was
the driver for Neil GOLDSCHMIDT, GIUSTO asked if he was off the record. PARSONS
stated he was not off the record, to which GIUSTO told PARSONS to go talk to Les.542
When asked if Bernard GIUSTO was seeing (Lee DOSS), GIUSTO asserted the whole world
could tell that they were together while he [Jim JEDDELOH] was in treatment.543 GIUSTO
asked PARSONS if she had spoken (to GRAHAM) and she stated he had. PARSONS asked
GIUSTO if he knew Robert KIM and he stated he did not.544 GIUSTO commented that he had
heard similar allegations against Bernard GIUSTO to what KIM had alleged. GIUSTO asked
PARSONS about what information she had received and PARSONS declined to share
information from her prior interviews.545 GIUSTO referred PARSONS back to ZAITZ and
PARSONS explained that reporters were bound by certain rules regarding sharing of information
as well as court decisions that uphold their right to protect their sources.546
542
Ex A17g, p 19
Ex A17g, p 21
544
Ex A17g, p 23
545
Ex A17g, p 26-27
546
Ex A17g, p 29
543

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34. Margie GOLDSCHMIDT Interview Questions

Background
Margie was married to Neil GOLDSCHMIDT, her confidant was GIUSTO, and she
subsequently was involved with GIUSTO romantically. It is thought that GIUSTO got his
information about GOLDSCHMIDTs crime, unsealing of divorce papers, and settlement
through Margie, whom he was dating. The victim and her mother were neighbors of Margie and
Neil. Margie and the victims mother worked together when Neil was Mayor.
1. How long have you known GIUSTO
2. When did you first meet GIUSTO
3. Describe your relationship with GIUSTO
4. At what time did your relationship move from professional to romantic
5. Did you confide in GIUSTO about concerns and issues at the time that he was the
Chief of Security for the GOLDSCHMIDT administration
6. Have you ever met Pam Durham
7. If so, when did you first meet her
8. What were the circumstances in which you met her
10. Did Pam Dunham ever work in the GOLDSCHMIDT administration or in state or city
government
11. Have you ever met Elizabeth Durham
12. If so, when did you first meet her
13. What were the circumstances in which you met her
15. When did you first discover that Neil had engaged in misconduct with Elizabeth
Durham
16. How did you discover this misconduct
17. Who told you about the misconduct
18. Were you involved in any discussions regarding the unsealing of your divorce papers
19. If so, who did you discuss this with
20. What was the purpose of discussing this event
21. Do you have siblings
22. What is the name of your brother
23. What is his contact information
24. Do you recall a time in which your brother had information about Neils misconduct.
25. Who did your brother tell about the misconduct
26. What did he say, specifics, when, where, others present
27. Do you recall telling GIUSTO about Neils misconduct
28. If so, what date was it, in relation to when you discovered it
29. What did you tell GIUSTO about Neils misconduct
30. Did you tell GIUSTO that Elizabeth Dunham was the individual that Neil had engaged
in misconduct
31. At any time did GIUSTO tell you that he had told LEONHARDT about Neils crime
32. Did you tell GIUSTO that you had to assist in getting your divorce papers unsealed

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33. At any time did you learn from your brother that Pam Durham had told him of the
misconduct between Elizabeth and Neil
36. How has it changed with each of your changing roles
37. When is the last time you spoke with LEONHARDT
38. Did you discuss Neils crime or associated information
39. Describe your understanding of the relationship between GIUSTO and LEONHARDT

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35. Margie GOLDSCHMIDT Interview Summary

On July 30, 2007, PARSONS and KING contacted Margie GOLDSCHMIDT by telephone.
PARSONS explained that DPSST was conducting an investigation based on various allegations.
GOLDSCHMIDT stated although she had not seen the allegations, she was aware of some of the
categories they fall into.547
PARSONS stated one allegation was that GIUSTO learned from Margie GOLDSCHMIDT about
Neil GOLDSCHMIDTs crime and might have used this information to blackmail Neil
GOLDSCHMIDT into promoting GIUSTO to Lieutenant. Margie GOLDSCHMIDT stated that
was the most ridiculous thing she had heard and that Neil GOLDSCHMIDT had nothing to do
with GIUSTO being promoted.548
PARSONS stated one allegation was that she had learned of Neil GOLDSCHMIDTs crime as a
result of Margie GOLDSCHMIDTs brother telling Neil GOLDSCHMIDT he was aware of it.
Margie GOLDSCHMIDT stated that that was not true, that her brother had never talked to either
Neil GOLDSCHDMIT or to GIUSTO as far as she knew.549 Margie GOLDSCHMIDT stated
that she had read LEONHARDTs letter and that she found at least twelve things that were
inaccurate. Margie GOLDSCHMIDT stated that she would not address private matters and
PARSONS assured her that her relationship with GIUSTO was not part of the scope of the
investigation.550 When told that information GIUSTO may have learned from their friendship
may be important to the investigation, she stated that, whatever and whenever he learned it . ..
was so far past this event. . .past the statute of limitations .. .there was nothing that he could have
done about it. Margie GOLDSCHMIDT asserted that there were other people that knew about it
perhaps when it was happening; therefore the notion that GIUSTO should have taken action was
ridiculous. 551
When asked when Margie GOLDSCHMIDT learned about Neil GOLDSCHMIDTs crime, she
stated that she did not know about it until Neil GOLDSCHMIDT was Governor. Margie
GOLDSCHMIDT stated she would not discuss what she may or may not have said to GIUSTO.
Margie GOLDSCHMIDT confirmed that she learned about Neil GOLDSCHMIDTs crime from
him, as opposed to a third party. When asked when GIUSTO learned about Neil
GOLDSCHMIDTs crime, Margie GOLDSCHMIDT stated that she did not know when he first
learned about the information, but, I do believed it was well after he started to work for Neil. . .
Im not aware that he knew anything about this prior to Neil becoming governor.552
When asked follow up questions about when GIUSTO found out, PARSONS asked, by the
time Neil left the position as governor . . seems more likely that he at least knew something
about it at that time. Margie GOLDSCHMIDT stated, Yeah . . he acknowledges that he did.553
547
Ex A21g, p 3
Ex A21g. p 9
549
Ex A21g, p 5
550
Ex A21g. p 6
551
Ex A21g, p 7
552
Ex A21g, p 8
553
Ex A21g, p 9
548

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When asked if GIUSTO was ever involved in any of the negotiations, Margie GOLDSCHMIDT
stated he was not.554 Margie GOLDSCHMIDT stated that the negotiations occurred after Neil
GOLDSCHMIDT had left office, and after their divorce.555
When asked about LEONHARDTs assertion that he and his wife socialized with Margie
GOLDSCHMIDT and GIUSTO and Ted KULONGOSKI and his wife Mary, she stated that they
did. Margie GOLDSCHMIDT then stated that those are the kind of things that GIUSTO doesnt
necessarily remember because he has a male brain.556
When asked if she did a lot of entertaining and whether GIUSTO may not recall who was at a
particular party, Margie GOLDSCHMIDT stated he wouldnt necessarily remember but added
that they were together for fifteen years and that she has always done a lot of entertaining.557
When asked if the LEONHARDTS were close friends of hers, Margie GOLDSCHMIDT, stated
that they were not. Margie GOLDSCHMDT pointed out that LEONHARDT has not had a job
since he was Neil GOLDSCHMIDTs speech writer, and that he is very angry because he didnt
get hired by the governor to be his speech writer. Margie GOLDSCHMIDT stated she does not
think that GIUSTO and LEONHARDT saw each other socially alone much at all. Margie
GOLDSCHMIDT characterized the relationship with the LEONHARDTS as part of Neils
office staff. . .in that sense. . .everybody socialized together. . . .they were not close friends to
Neil. . .we were all an office staff family.558
When asked if LEONHARDT shared the same relationship with Neil GOLDSCHMIDT that he
did with Margie GOLDSCHMIDT after the GOLDSCHMIDTS were divorced and after they had
left office, Margie GOLDSCHMIDT stated the relationship was more with her. When asked if
she socialized with Christy LEONHARDT, Margie GOLDSCHMIDT recalled a time that they
were all at a dinner with the governor and described it as partly because she wanted a chance to
talk to the governors wife, Mary; and that she is friends with her.559 Margie GOLDSCHMIDT
stated at that party there were only the six of them and that the conversation was focused on Ted
KULONGOSKI running for office.560
When asked if she thought Fred LEONHARDT had any animosity toward Neil
GOLDSCHMIDT, Margie GOLDSCHMIDT stated he had animosity toward the whole world,
and that Fred is just an angry person. Margie GOLDSCHMIDT stated that after Neil
GOLDSCHMIDT left office, Fred LEONHARDT was asked to write some speeches, which he
did, but later Neil GOLDSCHMIDT ended up handling his own matters.561
554
Ex A21g, p 10
Ex A21g, p 11
556
Ex A21g, p 12
557
Ex A21g, p 13
558
Ex A21g, p 14
559
Ex A21g, p 15
560
Ex A21g, p 16
561
Ex A21g, p 17
555

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Margie GOLDSCHMIDT asked if all of the input that people were providing was going to be
made public and PARSONS explained that it depended on how far the investigation went.
PARSONS asked again about Margie GOLDSCHMIDTs brother and she again stated that he
did not go to Neil. Margie GOLDSCHMIDT then stated that the young lady was never my
babysitter. When asked if the young ladys mother worked in the mayors office, Margie
GOLDSCHMIDT stated that she had, and confirmed that she was also a neighbor.562 Margie
GOLDSCHMIDT confirmed that her brother knew the neighbors, including the mother of the
victim, but that he did not have anything to do with telling Neil. Margie GOLDSCHMIDT
refused to provide the name of her brother but stated that she had asked him that question and
that he had denied talking to Neil GOLDSCHMIDT. Margie GOLDSCHMIDT agreed to
contact her brother and ask him to contact the DPSST investigators.563
When asked what precipitated Neil GOLDSCHMIDT telling Margie GOLDSCHMIDT about his
crime, Margie GOLDSCHMIDT stated the young lady had talked about suing him.564
Margie GOLDSCHMIDT asserted that she was aware of no party in which Neil
GOLDSCHMIDTs crime or related topics were discussed, nor did GIUSTO say that there was a
similar conversation occurring.565 Margie GOLDSCHMIDT stated that she continues to have a
good relationship with Neil GOLDSCHMIDT, but that a lot of what she knew was from reading
the newspaper. Margie GOLDSCHMIDT stated that she has chosen not to ask Neil
GOLDSCHMIDT questions about the prior events, and that there were people working for Neil
GOLDSCHMIDT that did not know, such as Tom IMESON. Margie GOLDSCHMIDT said she
was of the belief that Ted KULONGISKI and his wife Mary did not know. Margie
GOLDSCHMIDT stated that there were a few people that knew something and did not tell
her.566
Margie GOLDSCHMIDT stated that GIUSTO has no recollection of ever meeting the young
woman, and told her, Perhaps I was there having a drink with them. Maybe Id already left.567
Margie GOLDSCHMIDT stated there were other examples of inaccuracies in LEONHARDTs
statement. One was when he asserted that Neil GOLDSCHMIDTs new wife, Diana, found out
about his crime only when the woman brought suit; I know that Neil did not marry her without
discussing this with her.568 Another example concerning LEONHARDTs characterization of
the relevance of Neil GOLDSCHMIDTs alimony payment; Margie GOLDSCHMIDT asserted,
I am financially independent . . .he had to pay some alimony. . . Whatever the take was on the
alimony, it was not accurate.569 Margie GOLDSCHMIDT also disputed LEONHARDTs
account of her and GIUSTO showing up in matching costumes for a Halloween party. Margie
562
Ex A21g, p 19
Ex A21g, p 22
564
Ex A21g, p 22
565
Ex A21g, p 25
566
Ex A21g, p 27
567
Ex A21g, p 31
568
Ex A21g, p 32
569
Ex A21g, p 33
563

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GOLDSCHMIDT said, it was suggested we had planned that, and that was totally
inaccurate.570
Margie GOLDSCHMIDT stated that Neil GOLDSCHMIDT is not a pedophile, that it was one
incident. When asked if GIUSTO had any concerns about Neil GOLDSCHMIDT after learning
about his crime, Margie GOLDSCHMIDT stated he did not and that if he had seen other activity
he would have done something.571
570
571
Ex A21g, p 34
Ex A21g, p 38

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36. Neil GOLDSCHMIDT Interview Questions

Background
Former Governor of the state of Oregon. Prior to this he served as the Mayor of Portland. While
serving as the Mayor, raped a minor child known to him.
1. How long have you known Bernard GIUSTO
3. What was his position in your administration and related duties
4. How long did he work for you on the security detail
5. How has it changed with the changing roles
6. Do you recall a discussion about GIUSTOs promotion from sergeant to lieutenant?
8. Were you a part of the recommendation of GIUSTOs promotion
9. If so, what part did you play?
10. Did GIUSTO have any conversations with you about his position on the security detail
in relation to the promotion
11. If so, did this conversation factor into your recommendation to recommend him for
promotion
12. At any later point did you discover any information regarding the promotion, or
GIUSTOs discussion about the promotion that was different than you were led to
believe?
13. If so, what?
14. When did you first discover that GIUSTO was having a relationship with your wife
15. Who told you
16. What did they tell you
17. When did you first discover that someone other than you and the young woman were
aware of your relationship (margies brother, need name)
18. How did you discover this, who told you
19. Once you discovered that someone else knew about your relationship with the young
woman, what did you do then (tell wife)
20. At what point did you become aware that Margie had told GIUSTO about your
relationship with the young woman
21. How did you discover this
22. Did you have any discussions with GIUSTO about your relationship with the young
woman
23. Did GIUSTO ask you any questions about the event
24. Did you have more than one discussion
25. If so, how many, over what period of time
26. What were the topics of the discussion?
27. If so, when did these discussions occur and what was said.
28. At any point did you and GIUSTO have a discussion about keeping this information
confidential
29. If so, when and what was said

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30. At any point did you believe that if you did not assist GIUSTO in becoming a
Lieutenant he would disclose your relationship with the young woman
31. If so, what led you to believe this
32. Once you discovered that GIUSTO was having a relationship with Margie, why did
you continue to keep him on the security detail
33. At any point did you believe that if you did not keep GIUSTO on the security detail he
would disclose your relationship with the young woman
34. If so, what led you to believe this
35. Was there any other circumstances in which you altered the way you interacted with
GIUSTO because of a belief that if you did not, he would disclose your relationship
with the young woman
36. If so, what were the circumstances and when did they occur
37. Do you have any personal recollections regarding GIUSTOs knowledge of any
monies you provided to the young woman you had a relationship with
38. If so, what recollections
39. Did you and GIUSTO ever have a discussion about this topic
40. How long have you known Ruth Ann DOBSON
41. At any point did she come to you and tell you that she had learned that LEONHARDT
knew about your relationship with a young woman
42. If so, who did she tell you that LEONHARDT had learned this information from
43. Do you believe that either KANTOR or IMESON also knew what LEONHARDT had
discovered about your relationship with the young woman
44. If so, why do you believe this?
45. Did you take any action as the result of discovering that LEONHARDT had been told
these things?
49. How has it changed with the changing roles
50. Did you, GIUSTO and LEONHARDT ever socialize
51. If so, how frequently?
52. Where did you socialize
54. In your opinion, what was the relationship between GIUSTO and KULONGOSKI?
37. Neil GOLDSCHMIDT Interview Summary
On July 26, 2007, DPSST received the following telephone message, Ms. KING, this is Neil
GOLDSCHMIDT. You left your card at the house and we just got your letter today. I do not
intend to appear in this matter or answer any questions or involve myself in any discussions. I
have no interest in it at all, and the you know, obviously you have professional duty to
accomplish and I wish you all my best in all your work, but I do not intend to participate.

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38. Lee GRAHAM Interview #1 Questions

Background:
GRAHAM was formerly with the MCSO and moved through the ranks to Chief Deputy during
GIUSTOs administration. GRAHAM left MCSO and became employed with the Gresham
Police Department as an officer. GRAHAM has first-hand knowledge of many portions of
KIMs complaints.
1.
2.
3.
4.
5.
6.
7.
How long have you served in public safety

How long have you served with the MCSO
When did you first meet GIUSTO
What were the circumstances surrounding this event
When were you promoted to Chief Deputy; was it prior to or after GIUSTOs election
Did you have occasion to review a memorandum dated February 10, 2005 from Senior
Office Assistance Jeanne BROWN relating to her findings of a CCH check on Jim
JEDDELOH
8. What specific information did this CCH check include
9. What did you do with the information you received from BROWN
10. Describe the discussion you had with GIUSTO regarding JEDDELOHs criminal
background, regarding the DUII and the DV.
11. Was it normal practice for you to sign these licenses
12. If so, why did you defer to GIUSTO on this case?
13. Did you tell GIUSTO you would not sign the license approval
14. If so, why did you tell him that
15. Did you suggest that GIUSTO read the license application file
16. If so, why did you do so
17. After GIUSTO approved the license application by signing it, did you have a further
discussion with GIUSTO about JEDDELOHs criminal background
18. If so, what was discussed
19. In a regular license application process, would the sheriffs signature be the final step
in the process?
20. Are you aware of a time when a license application has been approved when the Proof
of Competency has not been included in the application
21. Are you aware of a time when a license application has been approved when the
required fee has not been paid?
22. Was it your belief that once the sheriff had signed the license application, that was the
same as approving it?
23. Who do you believe KIMs sources are
24. Do you have any knowledge of GIUSTOs reaction when the 2004 media broke the
GOLDSCHMIDT story, did he say he had prior knowledge

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39. Lee GRAHAM Interview #1 Summary

On July 17, 2007, PARSONS and KING interviewed GRAHAM at the Gresham Police
Department. The purpose of the interview was fact finding regarding his personal knowledge of
a series of events that were raised as allegations by KIM.
GRAHAM stated that he left MCSO because he disliked his job and he did not enjoy working in
management. Since he has been with Gresham PD, GRAHAM stated he has enjoyed his work as
a line officer.572
GRAHAM stated that he first met GIUSTO when they worked on common topics, while
GIUSTO was the Chief of Police at Gresham Police Department and GRAHAM was working at
MCSO. GRAHAM stated it was GIUSTO who promoted him to Chief Deputy.573 GRAHAM
described his relationship with GIUSTO as business associates and stated he does not socialize
with GIUSTO. GRAHAM stated that once he explained to GIUSTO why he was leaving,
although GIUSTO was surprised, he understood.574
When asked about the CHL for JEDDELOH, GRAHAM stated that when he received a report
from staff showing a domestic violence incident taken by PPB, he did not think JEDDELOH
should be issued a permit, that he was not going to sign it and that he referred the matter to
GIUSTO to sign it if he wanted.575 When asked if he would have normally referred the license
to GIUSTO, GRAHAM stated no. When asked why he referred it to GIUSTO, GRAHAM
explained that GIUSTO asked him to bring JEDDELOH in and start the process. Similar to
other influential people, they expedited the case.576 GRAHAM stated that after JEDDELOH was
fingerprinted and the paperwork was completed to begin the background process, several days
passed until the background investigator returned the application file to him indicating there was
a problem.577
GRAHAM stated he reviewed the file and as soon as he saw that there was a domestic violence
incident, he did not think JEDDELOH should be issued a handgun permit. GRAHAM stated he
took the application file to GIUSTO and met with him. GRAHAM stated that he specifically
recalled telling GIUSTO there was a domestic violence incident, that he didnt think he should
issue a permit and that GIUSTO needed to review the file himself. GRAHAM left the
application file with GIUSTOs secretary with the message that if GIUSTO wanted to sign off on
the permit he could do that as sheriff but that GRAHAM was not going to do so.578
When asked what GIUSTOs reaction was to GRAHAMs information on the domestic violence,
572
Ex A 37a, p 3
Ex A37a, p 4
574
Ex A37a, p 5
575
Ex A37a, p 6
576
Ex A37a, p 7
577
Ex A37a, p 8
578
Ex A37a, p 10
573

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and that he would not sign the permit [license], GRAHAM did not recall the specific words but
that it was similar to , Well, Ill review it later.579
GRAHAM stated that at a later point the application file was returned to him with what he thinks
was a sticky note on it with GIUSTOs signature saying, approved.580 GRAHAM stated he
recognized the handwriting on the sticky note as that of GIUSTOs.581 GRAHAM stated that
once GIUSTO had approved the CHL, MCSO staff called JEDDELOHs residence and left a
message for him to come in and complete other parts of the process. It was at this point that Lee
(Jeddeloh) DOSS called GIUSTO and discussed the domestic violence incident. GIUSTO,
according to GRAHAM, was having reservations about issuing the CHL and eventually it was
pulled and not issued.582
When asked if GRAHAM also mentioned the DUII to GIUSTO during the conversation in which
he had mentioned the domestic violence, GRAHAM stated, I believe I did. When asked what
impact the DUII would have had on the issuance of a CHL, GRAHAM stated, . . . normally it
would have excluded him from the process.583
When asked if GRAHAM was basing his personal choice not to approve the CHL on both the
DUII and the domestic violence, GRAHAM said he was, but that he was placing a lot more
weight on what he had read in the domestic violence reports.584
When asked, GRAHAM confirmed that the staff at MCSO understood that to complete the
application process JEDDELOH would complete a competency test and pay the fee; that it was
nobodys intent that these requirements be bypassed.585
When asked if GIUSTO explained why he had approved the CHL even after he was aware there
was a domestic violence and a DUII on JEDDELOHs record, GRAHAM stated he did not.586
When asked if he knew Robert KIM, GRAHAM stated he did not, and had not met him. When
asked if he was aware of any officer, sergeant or lieutenant transferring from Gresham Police
Department to MCSO, GRAHAM stated, zero that I know of.587 GRAHAM also knew of no
personnel coming from Gresham PD to MCSO when GIUSTO transferred.
When asked if GRAHAM was aware of a female employee that GIUSTO was contacting,
GRAHAM stated it was Deidra and that Sean CHRISTIAN had about croaked when she told
him she thought the sheriff liked her. GRAHAM stated it was he who called GIUSTO in and
told him it was not a good idea to date people in the work environment and he believed that
GIUSTO took his advice. Later, someone from HR contacted Deidra. GRAHAM stated he did
579
Ex A37a, p 11
Ex A37a, p 12
581
Ex A37a, p 13
582
Ex A37a, p 14
583
Ex A37a, p 15; p 38-39
584
Ex A37a, p 16
585
Ex A37a, p 17
586
Ex A37a, p 18
587
Ex A37a, p 19 20
580

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not think there was an investigation, that Deidra was not voicing a complaint, only talking to a
co-worker. When asked if GRAHAM recalled any threats to Deidra if she divulged the
information she would be fired, he stated, no. 588
When asked about an incident involving a comment of a racial nature, GRAHAM stated the
complaint was against Lt. RADER who referred to oreo during a roll call training, in reference
to a mentally ill subject being sandwiched between two boards as a restraint. GRAHAM
identified Rafael CORTADA as the complainant.589 GRAHAM did not think there was a formal
investigation; however he did counsel RADER. GRAHAM recalled that RADER adamantly
wanted to apologize to CORTADA but was not able to because of Union involvement.590
When asked if GRAHAM was aware of the GOLDSCHMIDT crime he stated that the only
information he had was what GIUSTO provided prior to the media release and indicated there
were going to be some things said about him that were not nice.591
When asked if GRAHAM had heard any rumors about GIUSTO and a female Gresham City
Councilwoman, GRAHAM identified the female as Jacquenette McINTIRE. GRAHAM stated
he was also a friend of McINTIREs and believed that GIUSTO was also just friends with her.592
When asked about emails on GIUSTOs computer from Lee DOSS, GRAHAM stated that he
was aware they were communicating, thought it was by telephone, and that he would not have
been privy to these communications.593
When asked, GRAHAM speculated that he believed GIUSTOs relationship with DOSS did not
begin until after the intervention.594
End of conversation
588
Ex A37a, p 21-27
Ex A37a, p 28-29
590
Ex A37a, p 30
591
Ex A37a, p 33
592
Ex A37a, p 34-36
593
Ex A37a, p 37
594
Ex A37a, p 41-42
589

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40. Lee GRAHAM Interview #2 Questions

1. When CHRISTIAN first reported his concerns about McGILL and GIUSTO, did he
do so to you, or to the sheriff, or both
2. GRAHAM asserted CHRISTIAN contacted both GIUSTO and GRAHAM
41. Lee GRAHAM Interview #2 Summary
On August 9, 2007, PARSONS conducted a follow-up telephone interview with GRAHAM for
clarification purposes.
When asked whether GRAHAM was alone when CHRISTIAN contacted him or if GIUSTO was
present, GRAHAM stated the first contact was with him alone, and a couple of days later, when
GIUSTO and GRAHAM were together, CHRISTIAN told GIUSTO what McGILL had been
saying about him.595
When asked why CHRISTIAN did not go through his chain of command, GRAHAM stated he
did not know but did know that CHRISTIANs sergeant was dealing with medical issues.596
When asked, GRAHAM stated he had not heard about McGILL being upset that someone had
gone to the sheriff, nor did he recall if McGILL was upset by being contacted by HR.597
End of conversation
595
Ex A37b, p 2-3
Ex A37b, p 3
597
Ex A37b, p 4-5
596

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42. Aimee GREEN, Oregonian

contact us.

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43. MCSO Deputy Mark HERRON Interview Questions

Background
NAITO named HERRON as an individual who may have information regarding this
investigation. NAITO provided no additional insights regarding the area of interest.
3. The reason that we have asked to speak with you is Commission NAITO gave DPSST
a number of names of MCSO employees to speak with in the belief you may have
information in the fact finding investigation that we are conducting.
4. Do you know Robert KIM
5. Do you know anyone who knows Robert KIM
44. MCSO Deputy Mark HERRON Interview Summary

On August 13, 2007, PARSONS and KING interviewed HERRON at his place of employment.
The purpose of the interview was a fact finding regarding his personal knowledge of any
allegations against GIUSTO.
After a review of HERRONs background, HERRON was advised that investigators were
speaking to him as a result of a conversation with NAITO who named him as an individual who
may have information, as a result of the KIM allegations. When asked if HERRON had looked
at the KIM allegations, HERRON stated he had not. When asked if HERRON knew KIM, he
stated he did not.598 HERRON identified himself as a member of the executive board for the
Union and in that position he had represented a number of union members.
When asked if he was aware of a racial harassment complaint, HERRON stated he was. When
asked if he was aware of any discipline as a result of this investigation, HERRON stated that
discipline and investigations were confidential matters, therefore it may never be general
knowledge.
When asked if HERRON was aware of an investigation against a female sergeant regarding
misuse of time, he stated he was not aware of whether there had been an investigation.599 When
asked about his knowledge of GIUSTOs contact with a female employee and whether it was
handled, HERRON stated he had no direct knowledge of that incident.600 Likewise with the
allegation of a female volunteer chaplain brought in by GUISTO, HERRON had no direct
knowledge.
598
Ex A57a, p 3
Ex A57a, p 5
600
Ex A57a, p 6
599

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When asked if HERRON believed that MCSO should be investigating the personal relationships
between employees, HERRON affirmed he did not think the agency should be, unless it blended
over into the work environment and there were consequences.601
HERRON stated he did not know KIM or anyone that knew him.
601
ExA57a, p 7

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45. OSP (ret.) James HINKLEY Questions

1. Background on purpose of call
2. What was your assignment during the GOLDSCHMIDT administration
3. When did you first learn about the GOLDSCHMIDT crime
4. If during the GOLDSCHMIDT administration, what did you do with this information
5. Were there any policies within OSP that required reporting of this information, even if
in rumor form
6. As a police officer, do you believe that a rumor about the rape of a child would
possibly lead to other victims or occuurances.
7. Do you have any recollections of GOLDSCHMIDTs activities which, in retrospect,
you may have attributed to GOLDSCHMIDTs contact with the victim or others
related to the victim
8. Did GIUSTO ever share any information about GOLDSCHMIDT and the underage
female
9. When did you first learn about GIUSTO and Margie GOLDSCHMIDT
10. If during the GOLDSCHMIDT administration, what did you do with this information
11. Did you have any personal observations of GIUSTO and Margie GOLDSCHMDIT
12. Do you believe that Neil GOLDSCHMIDT knew about any relationship between
GIUSTO and Margie GOLDSCHMIDT
13. Did you ever speak to GIUSTO about his relationship with Margie GOLDSCHMIDT.
14. If so, when do you believe he first knew about it, and why do you believe he did
15. Describe your knowledge of how GIUSTO was promoted to Lieutenant
16. Did you ever meet Fred LEONHARDT, if so, when and where
17. What was your relationship with Fred LEONHARDT
18. What was your assessment of Fred LEONHARDT
19. When have you last spoken to GIUSTO .
46. OSP (ret.) James HINKLEY Interview Summary

On October 4, 2007, PARSONS and KING conducted a telephonic interview with HINKLEY.
The introduction to conversation was not obtained due to a recording error.
HINKLEY identified that he shared the GOLDSCHMIDTs security detail along with GIUSTO.
When asked how many times he took GOLDSCHMIDT to BURTSCHAELL office , HINKLEY
stated three or four times and that he was instructed to remain in the vehicle. On one occasion, a
woman came out of the building and spoke to him. 602 HINKLEY described the woman as nice
looking and that he began to put two and two together, thinking that there may have been a little
tryst going on.603
HINKLEY stated that he and GIUSTO worked closely together but they were going in different
directions. When asked if HINKLEY was aware that GIUSTO was involved in a close personal
602
603
Ex A66g, p 2-3
Ex A66g, p 4

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relationship with Margie GOLDSCHMIDT, he stated that at one point he was and recalled a time
that he was at the Pendleton Roundup and a reporter from the Oregonian commented about
GIUSTO and Margie dancing and smoozing. HINKLEY stated he thought that was not a good
thing from a professional standpoint and he told the superintendents office about it because he
was concerned that GIUSTO was going to embarrass their department. HINKLEY stated he got
mixed reviews from the superintendents office and they did not know whether to believe what
he had told them.604
HINKLEY recalled an incident when he took GOLDSCHMIDT on a road trip and because
GOLDSCHMIDT became ill, he returned him to Mahonia Hall. When they arrived at Mahonia
Hall, they saw GIUSTOs vehicle parked in front and GOLDSCHMIDT asked what GIUSTO
was doing there. HINKLEY told GOLDSCHMIDT he did not know and the governor just kind
of came a little unhinged . . . he went storming into the house.605 HINKLEY believed that
GOLDSCHMIDTs security guard in the guard office knew something because he had seen him
[HINKLEY] and GOLDSCHMIDT leave. HINKLEY thought the guard was possibly Tad
Ashmore.606
When asked about GIUSTOs promotion, HINKLEY stated that he and GIUSTO were both
sergeants when they began the security detail and that GIUSTO had made lieutenant but
HINKLEY had not gotten promoted. HINKLEY described the promotion as a reward for
completing a four year stint with the governor.607 HINKLEY stated Rick GEISTWHITE was
brought in as GIUSTOs replacement when GIUSTO left.608
HINKLEY stated that after GIUSTO left, he continued on with GOLDSCHMIDT until
GOLDSCHDMIT left office. HINKLEY then left that assignment and due to a traffic crash, he
was injured, and eventually reassigned as the dispatch supervisor in Portland.609
When asked when HINKLEY heard about GOLDSCHMIDTs crime, he stated he read about it
in the newspaper. HINKLEY characterized himself as squeaky clean in terms of keeping the
superintendents office aware of things. HINKLEY stated that without a doubt . . .I was very
career minded . . .ethically I thought it was appropriate to tell the superintendents office if he
would have heard a rumor about GOLDSCHMIDT having a relationship with a girl, even if it
were a rumor.610 HINKLEY stated it was not something that he would have kept to himself.
When asked if there were any OSP policies that would have required him to report the rumor,
even if it were past the statute of limitations, HINKLEY stated that he still would have passed
the information along because of the predatory [nature]. HINKLEY stated it would have been
his responsibility to pass the information along, and to monitor things, because the governor was
604
A66g, p 5
Ex A66g, p 6
606
Ex A66g, p 7
607
Ex A66g, p 8
608
Ex A66g, p 9
609
Ex A66g, p 10
610
Ex A66g, p 11
605

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around young people.611 HINKLEY recalled that the stalking law was in effect and that he had
been a detective at one point prior to his promotion as a sergeant.
When asked if HINKLEY worked around Fred LEONHARDT, he stated he did. When asked
what HINKLEYs assessment of LEONHARDT was, he stated, really savvy, real intelligent . .
a nice guy.612
When asked if HINKLEY had heard any rumors about GOLDSCHMIDT and the girl,
HINKLEY stated that he had not but with forethought he would have put two and two together
when he saw the girl emerge from BURTSCHAELLs building.613 HINKLEY described the
woman as a white gal, maybe early 20s or mid 20s. HINKLEY recalled that the woman came
up and spoke with him saying, Hi. Hows it going tonight.614
When asked if HINKLEY ever spoke with GIUSTO about his relationship with Margie
GOLDSCHMIDT, he stated he was very uncomfortable about the whole situation because it
was not good for a State police security person to be messing around with the governors wife.
HINKLEY stated that he figured if the superintendents office wanted to get involved and
discipline him they could and then at one point GIUSTO was a Lieutenant and he was still a
Sergeant, therefore there was a chain of command issue.615
When asked when HINKLEY had spoken with GIUSTO last, he thought it was when he worked
for the Marshalls service at the courthouse, and then just in passing.616
611
Ex A66g, p 12
Ex A66g, p 13
613
Ex A66g, p 14
614
Ex A66g, p 15
615
Ex A66g, p 16
616
Ex A66g, p 17
612

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47. Tom IMESON Interview Questions

Background:
IMESON was GOLDSCHMIDTs chief of staff and later a business partner with
GOLDSCHMIDT. IMESON claims that KANTOR never told him about GOLDSCHMIDTs
crime and that if he had known he would not have had future business dealings with him.
1.
2.
3.
4.
5.
6.
7.
How long have you known GIUSTO

What was your relationship with him
How long have you known Gregg KANTOR
What was your relationship with him
Had GIUSTO ever confided his concerns about GOLDSCHMIDT with you
If so, what were his concerns, specifics
When did you first learn that GOLDSCHMIDT had committed a crime against a
young woman
8. Through what source?
9. Do you recall having a conversation with LEONHARDT around 1994
10. If so, did he contact you or did you contact him
11. Was the conversation in person or on the telephone
12. Did you discuss GOLDSCHMIDT
14. Did you discuss KANTORs knowledge of GIUSTOs allegations
15. Why would you have not continued your relationship with GOLDSCHMIDT if you
would have known about the crime
16. What do you recall about GIUSTO being promoted from Sergeant to Lieutenant?
17. Do you recall telling LEONHARDT that you felt that you (the office) had been tricked
into the promotion
18. Why do you feel so?
19. Did you later find out that what GIUSTO asserted, regarding the promotion, was
untrue?
20. Describe your knowledge of GIUSTOs promotion from Sergeant to Lieutenant and
how that came to be

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48. Tom IMESON Interview Summary

On August 6, 2007, PARSONS and KING met with IMESON at his place of business for the
purpose of fact finding regarding whether GIUSTO had knowledge of the GOLDSCHMIDT
crime.
IMESON stated he first became aware of GOLDSCHMIDTs sex crime a few weeks prior to it
becoming public. IMESON was GOLDSCHMIDTs chief of staff while he was the Governor.617
When asked if KANTOR ever told him about GOLDSCHMIDT and the young girl, IMESON
stated he could not recall. IMESON stated that he has talked to LEONHARDT about his
assertion that LEONHARDT told KANTOR, KANTOR told IMESON, and IMESON said, Tell
him to just forget about it. IMESON stated he cant imagine he would have said that and he
does not recall having that conversation with KANTOR.618
IMESON stated he has talked to KANTOR about LEONHARDT and KANTOR does not recall
going to IMESON either.619 IMESON stated he was not really involved in GOLDSCHMIDTs
personal life, only with what occurred at work. IMESON stated he was not aware of GIUSTOs
and Margie GOLDSCHMIDTs relationship until after GOLDSCHMIDT decided not to run for
re-election.620 IMESON stated at one point he had heard a rumor about GIUSTO and Margie
GOLDSCHMIDT and asked GIUSTO about it but he denied anything was going on.
IMESON stated he had no knowledge of the circumstances surrounding GIUSTO being
promoted from sergeant to lieutenant.621 IMESON stated that GOLDSCHMIDT did learn about
GIUSTO and Margie GOLDSCHMIDTs affair late in his term. IMESON returned to a prior
question about whether he knew of GOLDSCHMIDTs crime and IMESON stated that he
encouraged GOLDSCHMIDT to go through a thoughtful process about whether to run for reelection, and if he would have known about the underage girl, it wouldve been a no-brainer not
to run for re-election.622
IMESON stated when GOLDSCHMIDT decided not to run for re-election he called IMESON
and told him of his decision, stating, this campaigns headed into the ditch.623
IMESON stated that he was in a business partnership with GOLDSCHMIDT from the spring of
2000 until the press disclosures and it was about two weeks prior to the press release that
GOLDSCHMIDT had his new wife Diana, meet with IMESON at Bob BURCHELLs home and
tell him about the crime. Although Diana GOLDSCHMIDT did not tell him specifics, she did
tell him the essential facts, such as the girl was underage.624
617
Ex A24a, p 2
Ex A24a, p 3
619
Ex A4a, p 4
620
Ex A24a, p 5-6
621
Ex A24a, p 7
622
Ex A24a, p 8-9
623
Ex A24a, p 9
624
Ex A24a, p 11
618

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IMESON stated that while he was working for GOLDSCHMIDT in the Governors office, he
left about three weeks prior to the end of the term and LEONHARDT stayed on. According to
IMESON, LEONHARDT even wrote a letter to GOLDSCHMIDT telling him he should run for
President, therefore IMESON surmised that if the information LEONHARDT had against
GOLDSCHMIDT was an issue, it was not anything he expressed to IMESON.625 IMESON said
that LEONHARDT worked for various people after the GOLDSCHMIDT administration, such
as Vera KATZ. IMESON recalled seeing LEONHARDT and KANTOR a fair amount when
they worked together, although his office was away from theirs. After the GOLDSCHMIDT
administration IMESON recalled that they all met a couple of times for pizza, but those
gatherings gradually dissipated.
IMESON stated that since the GOLDSCHMIDT information came out, he and LEONHARDT
have gotten together and at that time LEONHARDT asked IMESON if he recalled a
conversation about GOLDSCHMIDT and he told LEONHARDT that he did not remember any
conversation.626
When asked if IMESON had any conversations with GIUSTO about the GOLDSCHMIDT crime
before or after the disclosure, IMESON stated he does not have a relationship with him.
IMESON recalled one time when GIUSTO invited him to his home for dinner, but that the
conversation was not about GOLDSCHMIDT.627
When asked about his knowledge of any of the circumstances surrounding GIUSTOs promotion
from sergeant to lieutenant, IMESON stated he was the contact for the Oregon State Police and
he does not recall ever having a conversation about anyones rank, although they had
conversations about security issues and budget issues.628
625
Ex A24a, p 14
Ex A24a, p 16
627
Ex A24a, p 17
628
Ex A24a, p 19
626

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49. James JEDDELOH Interview Questions

Background
JEDDELOH was married to Lee (Jeddeloh) DOSS. JEDDELOH, a member of the crime
commission, applied for a Concealed Handgun License (CHL) after speaking to GIUSTO about
it. Although first approved by GIUSTO, the approval was revoked because of JEDDELOHs
past criminal activity. DOJ conducted a criminal investigation of this matter. JEDDELOH was
also the subject of an intervention which involved GIUSTO and DOSS. DOJ conducted a
criminal investigation of this matter.
.
1. Regarding the CHL, did you promise GIUSTO any benefit or gain for processing your
license personally
2. Regarding the CHL did you promise GIUSTO any benefit or gain for processing your
license in an expedited manner
3. Did you disclose your DUII to GIUSTO at any time
4. Did you disclose your DV incident to GIUSTO at any time
6. Did GIUSTO ask for any benefit or gain for personally processing your license
7. Did GIUSTO ask for any benefit or gain for processing your license in an expedited
manner
8. In your opinion, when do you believe GIUSTO and Lee begin their relationship
9. What are you basing your beliefs on
10. Anything else that we should know.

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50. James JEDDELOH Interview Summary

On August 6, 2007, PARSONS and KING interviewed JEDDELOH at his residence. The
purpose was fact finding regarding the events surrounding the expedited CHL and GIUSTOs
relationship with JEDDELOHs wife.
When asked if JEDDELOH promised GIUSTO any gain for processing his CHL personally or in
an expedited manner, JEDDELOH stated no. JEDDELOH stated he already had a handgun
permit and because he was a member of the crime commission, the CHL was suggested to him
by another crime commission member who told him to see GIUSTO about it.629
When asked if JEDDELOH disclosed to GIUSTO his DUII or his domestic violence report,
JEDDELOH stated he did not know about the domestic violence report and did not include the
DUII on his application because he figured it would come up as a matter of course during the . .
. background check.630 JEDDELOH stated he did not have a conversation with GIUSTO about
his DUII.
When asked if GIUSTO asked JEDDELOH for any personal gain for processing or expediting
the CHL, JEDDELOH stated no.631
When asked when JEDDELOH believed the relationship between his wife and GIUSTO began,
he stated it was prior to the intervention. JEDDELOH was unable to provide a corroborating
evidence or admissions by DOSS, but surmised from events that their relationship had begun
prior to the intervention.632
JEDDELOH provided a three-page Clackamas County District Attorney memorandum regarding
domestic violence allegations which was summarized by the following analysis, After a careful
review of all relevant evidence it is clear that there is insufficient evidence to prove beyond a
reasonable doubt that James Jeddeloh assaulted Lee Jeddeloh. It is also clear that there is
insufficient evidence to prove beyond a reasonable doubt that James Jeddeloh willfully violated
the terms of the restraining order.633
End of conversation
629
Ex A32b, p 2
Ex A32b, p 3
631
Ex A32b, p 4
632
Ex A32b, p 4-6
633
Ex A32c
630

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51. Gregg KANTOR Interview Questions

Background
KANTOR was Communications Director for GOLDSCHMIDT administration, and the
LEONHARDTs supervisor. KANTORs supervisor was IMESON. LEONHARDT believes
that when he told KANTOR about GOLDSCHMIDTs crime, KANTOR bypassed IMESON
and went to Ruth Ann DODSON.
1. When did you first learn about any allegations of misconduct of Neil
GOLDSCHMIDT
2. What were the allegations
3. Who told you of the allegations
4. Did you receive information regarding the allegations from anyone else
5. If so, from whom?
6. Do you recall conversation with Leonhard about allegations of misconduct of Neil
GOLDSCHMIDT
7. If so, what did LEONHARDT tell you, specifics, age of victim, name of victim, when
the crime occurred
8. Do you recall where LEONHARDT told you he had gotten the information
9. What did you do with the information
10. Who did you tell about the allegations
11. What was there reaction
12. Did you make any conscience decision not to tell any individual
13. If so, who was that
14. Did you tell Ruth Ann DODSON
15. Did you tell IMESON
16. Do you recall returning to LEONHARDT and stating to him, you dont want to
know
17. If so, what did that mean
18. Did you believe the allegations that LEONHARDT was sharing with you
19. Do you recall meeting GOLDSCHMIDT and LEONHARDT for drinks at the old
Dakota Caf in downtown Portland and observing a young female approach your table,
look at GOLDSCHMIDT and nod her head yes when asked if she was on his
schedule?
20. When the young female approached, did you recognize her by name
21. Had you met her previous to this incident
22. Was there a purpose for this meeting?
23. Describe your knowledge of GIUSTOs promotion from Sergeant to Lieutenant and
how that came to be

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52. Gregg KANTOR Interview Summary

On August 13, 2007, PARSONS and KING met with KANTOR at his place of business
for the purpose of fact finding regarding whether GIUSTO had knowledge of the
GOLDSCHMIDT crime. KANTOR stated he was the communications director and press
secretary to GOLDSCHMIDT and as such he had contact with GIUSTO.
When asked if GIUSTO ever told him about his knowledge of GOLDSCHMIDTs crime
against the minor female, KANTOR stated he did not.634
When asked if LEONHARDT came to him and told him about GOLDSCHMIDTs
crime, KANTOR stated that LEONHARDT did. KANTOR stated that LEONHARDT
told him that he had heard from GIUSTO that Neil had had sex with an underage girl.
KANTOR could not recall when LEONHARDT told him this, but stated he had no
doubt that Freds recollection is probably about the timing. He was probably correct. It
was late in the administration.635 KANTOR commented that LEONHARDT kept a lot
of notes. KANTOR stated that he didnt believe it at the time and didnt think
LEONHARDT believed it at the time either. KANTOR thought perhaps GIUSTO was
upset with GOLDSCHMIDT because GOLDSCHMIDT wasnt particularly sensitive to
the needs of his staff members and GIUSTO may have felt slighted.636
KANTOR recalled innuendos coming out against GOLDSCHMIDT when he was up for
re-election, which were coming from campaigns against GOLDSCHMIDT and that there
was the thought that it was politically motivated.
When asked if LEONHARDT told KANTOR the name of the victim, he could not recall
whether LEONHARDT told him at the time or whether he heard it later.637 When asked
if LEONHARDT told KANTOR in what context he had learned of GOLDSCHMIDTs
crime from GIUSTO, he did not know; he just knew that GIUSTO and LEONHARDT
were friends. When asked why LEONHARDT told KANTOR, he said he thought
LEONHARDT was shocked. When asked about the timeframe of when
LEONHARDT learned of GOLDSCHMIDTs crime and when he came to KANTOR,
KANTOR stated he thought it was relatively soon after learning the information.638
KANTOR recalled that LEONHARDT wanted to know if he knew anything about the
crime. KANTOR stated that LEONHARDT thinks he went to IMESON with the
information but KANTOR does not ever remember going to IMESON.639 KANTOR
stated, I just wrote it off . . . it was just way too bizarre. KANTOR recalled that he
assumed that GIUSTO had heard of the crime from other people in other campaigns . . .
and was angry at Neil and was spreading it around.640
634
Ex. A23a, p 3
Ex A23a, p 4
636
Ex A23a, p 5
637
Ex A23a, p 6
638
Ex A23a, p 8
639
Ex A23a, p 9
640
Ex A23a, p 11
635

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KANTOR stated that he found out about GIUSTO and Margie GOLDSCHMIDT later in
the [GOLDSCHMIDT] administration.641
KANTOR stated he had never spoken to Ruth Ann DODSON. KANTOR stated that he
chalked what LEONHARDT had told him up to another one of the rumors, and when
he found out about GIUSTO dating Margie GOLDSCHMIDT, he thought GIUSTO could
have been spreading the rumor because he was angry with Neil GOLDSCHMIDT.642
KANTOR stated he was present at the Dakota Caf, along with LEONHARDT and
GOLDSCHMIDT but stated, I dont remember the woman,643 asserting it was dark
and people would see GOLDSCHMIDT and approach him. KANTOR did recall
LEONHARDT later telling him that the woman approached them,644 but that he would
not have known who she was at the time. KANTOR did recall LEONHARDT
identifying a woman as the one that GIUSTO had told him GOLDSCHMIDT was
involved with. KANTOR recalled that the general timeframe for this conversation was
between 1989 and 1991.645 KANTOR also recalled that LEONHARDT pointed the
woman out to him within months of them visiting the Dakota Caf.646 KANTOR
surmised that because GIUSTO was with Margie GOLDSCHMIDT, she apparently told
him and then LEONHART got the information from GIUSTO.647 KANTOR stated that
he did not believe what LEONHARDT had told him until Neil announced that it was
true.648
KANTOR stated that he and LEONHARDT had a conversation on the day that the
GOLDSCHMIDT story hit the news.649 KANTOR recalled LEONHARDT being very
angry at GOLDSCHMIDT and at KULONGOSKI. When asked why LEONHARDT
would be mad at KULONGOSKI, KANTOR said it was because KULONGOSKI had
appointed GOLDSCHMIDT to the Higher Ed board even though he had told
KULONGOSKI about GOLDSCHMIDTs crimes earlier.650
KANTOR stated that he has no reason to believe that anything that hes
[LEONHARDT] saying is inaccurate. KANTOR said that LEONHARDT was an
emotional person and had been upset at KULONGOSKI because he felt he was treated
poorly and that when they would get together, the conversation would always gravitate to
someplace where he would then become angry.651 KANTOR stated LEONARDT was
641
Ex A23a, p 12
Ex A23a, p 13
643
Ex A23a, p 15
644
Ex A23a, p 16
645
Ex A23a, p 17-18
646
Ex A23a, p 20
647
Ex A23a, p 21
648
Ex A23a, p 21
649
Ex A23a, p 22
650
Ex A23a, p 23
651
Ex A23a, p 26
642

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almost more angry at KULONGOSKI for making GOLDSCHMIDTs appointment than
at GOLDSCHMIDT.
KANTOR stated that when KULONGOSKI told the media he did not know about
GOLDSCHMIDTs crime, LEONHARDT became more upset and asserted to KANTOR
that you better tell Steve. . . .I told Ted . . . KANTOR stated he spoke to Steve
SNYDER, KULONGOSKIs chief of staff, later and SNYDER felt that KULONGOSKI
had never been told about GOLDSCHMIDTs crime by LEONHARDT.652
KANTOR stated that he believed that there were series of conversations between
GIUSTO and LEONHARDT and LEONHARDT may have learned more than from the
initial meeting. KANTOR stated that he did not hear of any pay-offs, and that he did not
hear any information directly from GIUSTO.653 KANTOR assessed LEONHARDT as an
emotional but honest guy and reiterated that he had no reason to believe that anything
LEONHARDT was saying was untrue.654
When asked what specifically LEONHARDT told KANTOR about what GIUSTO had
told him, KANTOR recalled that it was when GOLDSCHMDIT was the mayor and that
the girl was underage and that he had sex with her. Later, LEONHARDT specifically
identified the woman at the Dakota Caf which led KANTOR to believe there were
ongoing conversations between GIUSTO and LEONHARDT.655 KANTOR did not
recall if LEONHARDT told him that the victim was a neighbor of GOLDSCHMIDT.
KANTOR did know that the victims mother worked in GOLDSCHMIDT administration
but did not recall if it was LEONHARDT or someone else who told him.656
KANTOR affirmed that there were other individuals that were coming to him and telling
him about GOLDSCHMIDT having a relationship with an underage girl, other than
LEONHARDT., but it was after they were out of office.657 When asked if these other
people were credible, KANTOR stated not really, it was just a lot of rumors. KANTOR
stated some acquaintances who were lawyers had heard of it, but he could not recall their
names.658
When asked if KANTOR and KULONGOSKI ever had a conversation about the rumors,
KANTOR initially stated they did not, but then recalled a time after GOLDSCHMIDT
announced his crimes that he and KULONGOSKI met on the street and KULONGOSKI
told him that he could not recall LEONHARDT telling him about the crime.
On follow up, when asked if KANTOR shared what LEONHARDT had told him with
anyone else, KANTOR stated he did not think so.659 KANTOR could not recall the
652
Ex A23a, p 28
Ex A23a, p 30
654
Ex A23a, p 01
655
Ex A23a, p 32
656
Ex A23a, p 33
657
Ex A23a, p 34
658
Ex A23a, p 35
659
Ex A23a, p 36
653

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timeframe from when LEONHARDT told him what GIUSTO had told him to the Dakota
Caf event.660
KANTOR had no recollection of the circumstances surrounding GIUSTOs promotion
from Sergeant to Lieutenant. KANTOR stated he had personal knowledge of Neil
GOLDSCHMIDT being aware that Margie GOLDSCHMIDT was seeing GIUSTO.661
KANTOR stated he and GOLDSCHMIDT were on a trip out of state and
GOLDSCHMIDT called him into his room and told him that Margie GOLDSCHMIDT
was having an affair with GIUSTO. KANTOR surmised that this was in late 1989 or
early 1990, and before GOLDSCHMIDT announced he would not seek re-election.662
When asked if GIUSTO was still working GOLDSCHMIDTs security detail during the
time he was seeing Margie GOLDSCHMIDT, KANTOR thought it was right around that
time when GIUSTO left and GIESTWHITE, an Oregon State Police trooper, came onto
the security detail.663 KANTOR described GOLDSCHMIDT as upset and depressed
about the information about Margie GOLDSCHMIDT and GIUSTO.
End of conversation
660
Ex A23a, p 37
Ex A23a, p 39
662
Ex A23a, p 40
663
Ex A23a, p 41
661

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53. Debby (Stone) KENNEDY Interview Questions

Background
During the GOLDSCHMIDT administration KENNEDY and GIUSTO dated. KENNEDY told
LEONHARDT that GIUSTO told her about GOLDSCHMIDTs crime when they were dating.
KENNEDY also called LEONHARDT when the 2004 story broke and gave him a phone hug.
At that time KENNEDY was working as the Director for Tourism, a position appointed by
KULONGOSKI, she has since left state government.
1. How long have you known GIUSTO, describe your relationship with him
2. What were the circumstances that you first met GIUSTO
3. Do you recall GIUSTO telling you anything about misconduct involving
GOLDSCHMIDT
4. What do you recall him telling you
5. When did GIUSTO tell you this
6. Why do you think GIUSTO told you this
7. Did you share what GIUSTO had told you , or a portion of it, with any other person
8. If so, who were they?
11. When is the last time you spoke with him
12. Do you recall a conversation you had with LEONHARDT after the story broke?
13. Did you call him or did he call you?
14. Did you call his home?
15. How did you have LEONHARDTs phone number?
16. What was the purpose of the call
17. Had you read the article about GOLDSCHMIDT and LEONHARDTs involvement in
disclosing this information
18. What did you tell LEONHARDT about your knowledge of GOLDSCHMIDTs crime
19. Do you recall speaking with a news reporter about what GIUSTO had told you about
GOLDSCHMIDTs crime
20. What did you tell him/her?
21. I note that after you spoke to the reporter, you have since left state government, did
you retire?
22. Did speaking to the media have a role in your leaving state government
23. Do you believe you suffered any repercussions as a result of speaking with the media

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54. Debby (Stone) KENNEDY Interview #1 Summary

On July 18, 2007, KING spoke with STONE on the telephone.
KING advised KENNEDY of the purpose of the contact with her. KENNEDY expressed
concern about her name being used in a document that would later be available to the public.664
KENNEDY asked KING what the focus of questioning would be and KING identified the areas
as what KENNEDY was told by GIUSTO about Neil GOLDSCHMIDTs crime, when she was
told this information, and what she told LEONHARDT about her knowledge of the Neil
GOLDSCHMIDT crime.665
KENNEDY expressed concern about GIUSTO being a powerful and hurtful person and KING
explained that regardless of the status of an individual, all public safety officers were held to the
same standard. 666
KENNEDY questioned whether GIUSTOs relationship with Margie GOLDSCHMIDT was an
issue for DPSST and KING explained that the focus of the states interest in KENNEDY was not
regarding that relationship.667
When asked what KENNEDY recalled about what GIUSTO had told her, KENNEDY stated that
right before Neil GOLDSCHMIDTs announcement he was not running for re-election, GIUSTO
shared some information, but not specifics. When asked if GIUSTO identified the victim by
name, KENNEDY said he did not.668 When asked if GIUSTO told KENNEDY if the victim was
female, KENNEDY said that he did state she was female. When asked if GIUSTO told
KENNEDY how old the victim was, KENNEDY stated that GIUSTO said she was way under
age.669
KENNEDY again expressed her concern about who would see the report, and KING identified
the process from Policy Committee and to the Board.670 When asked if the media would see the
information KING confirmed that at some point they would.671 KING asked KENNEDY about
her conversation with LEONHARDT after the media story broke. STONE stated that she may
have talked with LEONHARDT the day the story broke and that she was in shock. KENNEDY
stated GIUSTO was a bad man and a very gifted liar, and she was scared of him.672 KING
explained that she was not able to offer immunity, protection or privacy but explained that if
there was misconduct, it would be better to address it rather than allowing it to continue.673
KENNEDY explained that she was particularly concerned about hurting Margie
664
Ex A20d, p 2
Ex A20d, p 3,5
666
Ex A20d, p 4,
667
Ex A20d, p 6
668
Ex A20d, p 8
669
Ex A20d, p. 9
670
Ex A20d, p 10
671
Ex A20d, p 11
672
Ex A20d, p 12
673
Ex A20d, p 12
665

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GOLDSCHMIDT, who had already been hurt. KENNEDY explained that after GIUSTOs
relationship with Margie GOLDSCHMIDT, and when he was seeing Lee DOSS, KENNEDY
had confided to Margie GOLDSCHMIDT other lies that GIUSTO had told both of them and
that because Margie GOLDSCHMIDT didnt know about them, it completely shattered her
memory of her years with Bernie.674 Later, KENNEDY apologized to Margie
GOLDSCHMIDT, explaining that she had shared the information in the belief that she was
protecting Margie GOLDSCHMIDT from this really bad man. KENNEDY expressed
reluctance to open up anybodys old wounds . . .so many people have been hurt by Bernie.675
KENNEDY related how she had handled a prior inquiry from the media; that she asked that her
husband be present. KENNEDY then stated she wanted to speak with her husband and KING
agreed to leave the door open. KENNEDY then related that she was aware of other
information about GIUSTO that had not been asked, but later in the interview, identified that the
information related to GIUSTOs lack of morality or morals and in light of the states
jurisdiction, it would not be pertinent.676
KENNEDY asked where the State was in their investigation and KING explained that we could
not disclose that, but that we were taking the opportunity to talk with a number of individuals.677
KENNDY then asked if her information could be off the record and KING stated that she would
pose the question to Oregon Department of Justice, 678but also explained the right for someone
accused of misconduct to face their accusers. KENNEDY asked if this matter could end up in a
courtroom and KING explained that there was a possibility for it to go to a contested case
hearing in front of an administrative law judge.679
KENNEDY asked about the minimum standards and KING described them, but emphasized that
the State does not determine an individuals morality, but rather the conduct that would affect a
police officers ability to perform competently and have the publics trust.680 KENNEDY
affirmed that the additional information she had dealt with morality issues.
KENNEDY confirmed that GIUSTO had told her about Neil GOLDSCHMIDTs crime, that the
conversation was fairly vague and KENNEDY confirmed that she had knowledge that
GIUSTO was aware of Neil GOLDSCHMIDTs crime right before he decided not to run for reelection.681
Regarding her conversation with LEONHARDT, KING asked what she recalled about that
conversation. KENNEDY stated that she did not recall a darn thing about that conversation,
other than being shocked.
End of conversation
674
Ex A20d, p 13
Ex A20d, p 14
676
Ex A20d, p. 16, 22, 23
677
Ex A20d, p 19
678
Ex A20d, p 20
679
Ex A20d, p 21
680
Ex A20d, p 22
681
Ex A20d, p 24
675

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55. Debby (Stone) KENNEDY Interview #2 Summary

On July 20, 2007, KING contacted KENNEDY via telephone, in response to KENNEDYs call
to DPSST.
KENNEDY told KING that she had been concerned about a prior characterization of her
conversation with LEONHARDT. KENNEDY asserted that she did not call LEONHARDT to
congratulate him, but that because she was worried about him and thought that he may have
been upset.682 KENNEDY stated she called LEONHARDT to ask, Are you okay?
KING asked KENNEDY to confirm that in that conversation she shared with LEONHARDT
that GIUSTO had also told her about his knowledge of Neil GOLDSCHMIDTs crime and
KENNEDY did confirm this fact.683 In response to KENNEDYs inquiries as to why this was
important, KING explained that the State was seeking information to corroborate prior
information.684 KENNEDY stated that she recalled the event very vividly. When asked about
specifics, KENNEDY stated that she was at her home, and GIUSTO came over and said, Neils
going to announce that hes not running again, GIUSTO then told her, Part of its because this
things going to come out about this underage girl. But the other reason is because Im having
an affair with Margie.685 KENNEDY stated that she was shocked about the revelation about
GIUSTO and Margie GOLDSCHMIDT because she and GIUSTO had been dating; therefore her
focus was on his affair with Margie GOLDSCHMIDT.686 KENNEDY stated that after this she
does not recall ever talking to GIUSTO again.687
When asked how long KENNEDY thought GIUSTOs affair with Margie GOLDSCHMIDT had
been going on, she surmised for a long time and prior to her relationship with GIUSTO.688
KING asked KENNEDY if she could send a draft Affidavit for her review and KENNEDY
provided her email address.689 KENNEDY again wanted to clarify that she had not called
LEONHARDT to congratulate him, but to give him a phone hug and ask if he was okay.
When KING read back to KENNEDY what LEONHARDT stated about KENNEDY telling him
that GIUSTO sharing the same information about Neil Goldschmidts crime with her,
KENNEDY confirmed that it was accurate.690
End of conversation
Subsequent to this interview, investigators emailed KENNEDY a draft affidavit and she did not
provide a notarized affidavit.
682
Ex A20e, p 2-3
Ex A20e, p 4
684
Ex A20e, p 5
685
Ex A20e, p 7
686
Ex A20e, p. 8
687
Ex A20e, p 9
688
Ex A20e, p 11
689
Ex A20e, p. 13
690
Ex A20e, p 14
683

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56. Robert KIM Interview #1 Questions

Robert KIM, complainant
Personal involvement in any of the allegations?
Related to anyone with personal involvement in any of the allegations
Motive?
History with public safety?
First-hand knowledge?
Fact vs. unsubstantiated antidotal
Following KIMs allegation numbering:
2.a. Law Enforcement Command Staff Lieutenant (identify)
Date of Incident
Agency
Complainant/victim
Specific allegation(s)
Follow up with outside investigators
2.b. Law Enforcement Sergeant (identify)
Date of incident
Agency
Complainant/Victim
Specific allegations(s)
2.c.Female Law Enforcement Sergeant
Date of incident
Determine if instigation means allegation fabricated, poorly investigated,
artificially inflated, or other
Agency
Complainant/Victim
Specific allegations(s)
What importance is the gender of the attorney?
3. Who were the state investigators?
Date of investigation
What were they investigating
What did Giusto lie about
When did Giusto lie to investigators
What did he lie about
When did Giusto lie to reporters
What did he lie about
When did Giusto lie to members of MCSO
What did he lie about?
When did Giusto lie to the public
What did he lie about?
4. Ms. Lee Doss
Relationship to Giusto
Related incident involving Doss
Communications with Giusto

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Type of communications, personal, sexual, business?
5.a.Identify who has first-hand knowledge of:
Date of incident
Goldschmidts spouse (former?)
What was the relationship
What did Giusto do improperly while acting in capacity as a OSP Sgt?
Public/agency knowledge?
5.b.Goldschmidts abuse of a child
Was there abuse?
Was it reported (by doctors, others)
Over what period of time
What was the outcome?
Were there mandatory reporting laws at the time?
5.c. Who was the member of the Gresham City Council
What was the conflict?
Were there professional or on-duty consequences to the personal relationship
which lie within DPSSTs jurisdiction?
What was the relationship? (family, sexual, business)
Public/agency knowledge
5.d.Who was the employee of MCSO (Female Special Investigations Staffer)
What was improper about the contact
Clarify the threat
What was the reason for HR to threaten the female
What did the threat involve?
Who was a witness to the threat?
5.e. Who was the supervising Chaplain?
Who was the volunteer Chaplain?
Why was the conduct improper?
What were the professional consequences that lie within DPSSTs jurisdiction?
(Supervising Chaplains contract)
Who was the Chief Deputy?
5.f. Who was the PPB employee that Giusto was pursuing
What does personal gratification mean
How does complainant know there was no professional purpose
Was complainant present at retirement party?
Who was the retiree (Sgt)?
How does complainant know that Giusto did not have a personal connection
retiree?
How is this conduct within DPSSTs jurisdiction?
5.g. Who was the citizen who received the Concealed Handgun License?
What is the relationship between Giusto and this citizen?
Did Giusto have the authority to sign this document?

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Did Giusto have prior knowledge of DV history
What specifically did Chief Deputy Graham provide to Giusto about the DV and
alcohol history
What is the relationship between Giusto and Graham?
What impact would the Chair of citizen crime commission have on Giustos decision
to approve permit?
Were there subsequent professional consequences that lie within DPSSTs
jurisdiction?
5.h. To whom did Giusto make a false statement regarding the permit (media)?
What did he say that was false?
Did Giusto read staff reports prior to approving permit?
Who were the staff reports (plural) from?
What did they contain?
Which Chief Deputy resigned?
What action (inaction) did the Chief Deputy take on the issuance of permit? (refusal
to sign for issuance)
5.i. Who has personal knowledge of Giustos direction of cover-up
Who did Giusto direct to cover up?
What did Giusto direct this person to do?
What were the consequences?
How was the file altered?
What were the professional consequences that lie within DPSSTs jurisdiction?
5.j. Which judge issued a protective order, and to whom was it issued?
Date of issue, associated documentation
How did Giusto manipulate the Order?
How did Giusto misuse the Order?
How did Giusto use the Order in a quid pro quo situation?
Which officer obtained the Order
Which officer served the Order
Was there a time delay? If so, why?
What was the outcome of the Order
Were there any consequences to the delay of serving the Order?
5.k. Who is the spouse of the Chair of the Commission?
What is Giustos relationship with her? (personal, sexual, professional)
How did Giusto endanger the spouse?
What would be the purpose of Giusto first issuing a Concealed Weapons Permit to a
husband and then a Protective Order to the wife?
What was the span of time of the two events
Is there factual information that the relationship between any of them changed
during this time?
5.l. To whom did Giusto make false statements? (media and public)
What were the false statements?
How were the phone calls obtained? By whom? Over what period of time?
Who found insurance documents?
Where were they found
When were they found

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6. Who has lost confidence in MCSO?
Was it under the purview of the Board of Multnomah County Commissioners
(Commissioners) to make a moral fitness inquiry?
How would moral fitness disqualify Giusto under the Commissioners scheme?
What authority do the Commissioners have over Giusto since is he an elected
official?
7. What merit did DA Shrunk find in the request of the Board[Commissioners]
What was the Commissioners request?
Who referred the information to DOJ?
Who in DOJ handled the investigation?
What was the scope of the investigation?
What facts support an assertion of political connections tainting the final report
outcome?
8. Who in the IACP rebuked Giusto?
What was said?
Is there policy against appearing in uniform for a political candidate?
What facts support the assertion of political collusion between the state attorney
general, the governors office and Giusto?
What special treatment did Giusto receive?
9. Who prepared the detailed report in the Multnomah County District Attorneys Office?
What was the scope
Was there a recommended plan of action/improvement?
10. How do arrests of Giustos subordinates correlate to his conduct?
11. Has there been a single reporter or multiple reporters on Giusto?
Could Giusto have impacted whether the news articles were written?
Where did the complainant obtain the moral turpitude: definition?
If this is a part of MCSO policy, how does Giustos conduct violate the policy?
Did anyone assist you in drafting the letter, if so whom
Where did you get the format from, such as the Code of Ethics and OARs
Who are your sources? Have you contacted them and advised them that DPSST
would like to speak with them?
MCCAINs promise to maintain confidentiality of sources until contested case
hearing, if case moves there,
Alternative is to have DPSST seek to determine who the sources are through the
process of elimination.

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57. Robert KIM Interview #1 Summary

On May 22, 2007, PARSONS and KING met with KIM at his residence for the purpose of
following up on the letter he wrote to DPSST in which he cited complaints about Sheriff Bernard
GIUSTO. KIM stated he had never met GIUSTO691 and that he had obtained all of his
information from various news articles and from his friends whom he described as working for
the Multnomah County Sheriffs Office.692 KIM stated that over a period of seven or eight
months he and his friends would get together, have a few beers and watch games together and
this is where they would complain to KIM. One friend was described as a deputy sheriff.693
KIM also asserted that his friends knew he had written the letter and condoned it but that
they did not want to get involved. KIM further asserted that theres no first-hand information
whatsoever.694 As a result of the letter he had written, KIM expressed concern about GIUSTO
checking his background, and that his uncle, John LIM had asked him to recant his statements.
695
LIM expressed concern because, according to KIM, he is an honorary deputy with MCSO.696
KIM identified a Lieutenant LONG as an individual who made an insensitive remark of oreo
during a morning briefing. KIM was unsure if his buddies were present during this
conversation. KIM stated that there was a complaint made and that the complaint went up the
chain of command but GIUSTO just squashed it.698 KIM later asserted that, There was no
investigation.699 When questioned about an outside investigation KIM asserted that in cases
such as racial harassment, MCSO hires an outside agency to investigate the allegations but that it
did not occur in this case.700 KIM further asserted that, there was no investigation . . . internally
or outside. KIM stated that the officer who was offended mentioned it to my buddy and then
someone else made the complaint on his behalf.701
697
When asked about KIMs allegation of failure to investigate misconduct against a law
enforcement sergeant involved with another members wife, KIM indicated he would come back
to this issue.
KIM stated that in the next allegation, a female sergeant was reprimanded for something that she
did not do because someone did not like her. KIM asserted that the basis of the allegations
involved misuse of leave time and the female sergeant ended up filing a grievance, hired a
female attorney and that it turned out that it was not her fault.702 KIM stated he had received
691
Ex A1c, p 1
Ex A1c, p. 2
693
Ex A1c, p9
694
Ex A1c, p 5
695
Ex A1c, p 8
696
Ex A1c, p 10
697
Ex A1c, p 13
698
Ex A1c, p15
699
Ex A1c, p 16
700
Ex A1c, p 18
701
Ex A1c, p 17
702
Ex A1c, p 20
692

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this information from his friend.703 KIM stated he believed that Lieutenant LONG was the
individual that did not like the female sergeant.704
When asked about KIMs allegation that GIUSTO had lied to investigators, reporters, member of
the MCSO and the public, KIM asserted that this pertained to the GOLDSCHMIDT
administration when GIUSTO was a driver. When he was asked by the Oregonian what he knew
of GOLDSCHMIDTs crime and when he knew about it, GUISTO stated I dont recall and I
dont remember.705 KIM stated that because of what he had read in the newspapers regarding
the young woman, GIUSTOs affair with Margie GOLDSCHMIDT, and because GIUSTO was
GOLDSCHMIDTs driver, he had a theory that GIUSTO was present during a payoff.706
When asked about KIMs allegation that GIUSTO lied to investigators through deceit or tacit
refusal to cooperate fully, KIM stated that GIUSTO had violated county policy when he sent
personal messages to Lee DOSS. KIM stated that he had verified with his buddy that MCSO
had a policy on email usage.707
KIM referenced an article written about Fred LEONHARDT who identified misconduct
involving GIUSTO having an affair with Margie GOLDSCHMIDT, GIUSTOs knowledge of
Neil GOLDSCHMIDTs crime of sex with a 14-year old female and GIUSTOs failure to report
the crime.708 KIM concluded that a powerful man like Neil GOLDSCHMIDT he doesnt do
his dirty deeds. . . he let his underlings do all his dirty deeds. . . it makes sense that he [GIUSTO]
knew about that.709
When asked about GIUSTOs personal relationship with a member of the Gresham City Council
while he was Police Chief, KIM stated GIUSTO was having an affair with her while she was
his boss.710 KIM identified his sources as his number three friend who was also with the
Gresham Police at the time.711 When asked if their personal relationship had any ramifications
on the councilwoman or on GIUSTO, KIM had no information, asserting that it was improper
because it had occurred in the workplace.712
Regarding KIMs allegation about GIUSTO having improper contact with a female employee of
MCSO, he stated that his information had come from number two friend and that GIUSTO
began to email her with messages such as, I like you. GIUSTO then sent her flowers and
wine. Ultimately a chief deputy told GIUSTO that he could not be sending such messages and
then sent the human resource director to scare the hell out of her.713 KIM identified the female
employee as Jennifer OTT. KIM stated OTT was told that she could not mention any of the
703
Ex A1c, p 22
Ex A1c, p 23
705
Ex A1c, p 25
706
Ex A1c, p 27
707
Ex A1c, p 28
708
Ex A1c, p 30-31
709
Ex A1c, p 30
710
Ex A1c. p 33
711
Ex A1c. p. 33
712
Ex A1c, p 34
713
Ex A1c, p 36
704

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emails and that she was threatened by the human resource director.714 KIM first identified his
sources as number three two guy who observed OTT shaking after speaking with the human
resources director, but later stated he was not sure whether this friend was present for this
conversation.715
When asked about the allegation of GIUSTOs improper conduct with a female volunteer
chaplain, KIM asserted that he heard from his two of his buddies that the 82-year old chaplain
had his salary cut from $80,000 to $40,000 as a result of GIUSTOs relationship with the female
volunteer and that there was a rift between the volunteer chaplain and the supervising
chaplain.716
When asked about the allegation of GIUSTO pursuing a Portland Police Bureau employee at a
retirement for personal gratification, KIM identified Karl McDADE, a retiring Portland Police
Bureau Sergeant, as the person whom the party was for. KIM stated one of his friends told him
that GIUSTO had no business at the party but was there to talk to Angela [OSWALT]. KIM
then disclosed that a Portland Police officer had told his friend about this event. When asked
what KIM meant by personal gratification, KIM stated that it was because GIUSTO was there
to speak with Angela, although GIUSTO left the event alone.717
When asked about the allegation of GIUSTO issuing a concealed handgun license, GIUSTO
stated that he obtained his information about this event from the media.
When asked about the allegation of GIUSTO making a false statement about his reasons for
approving the license, and that GIUSTOs actions contributed to the resignation of the Chief
Deputy, KIM asserted that he learned of this from his buddy. KIM stated that his friend did
not talk to the Chief Deputy about his reasons for resigning.718 When asked about what KIM
believed the false statements were, KIM stated that when Lee DOSS called GIUSTO after
hearing about GIUSTOs approval of the license, she told GIUSTO about the domestic violence
and alcohol problems. Then, when the Oregonian contacted him, GIUSTO asserted he didnt
know about [JEDDELOHs] prior history. KIM surmised, . . .it makes sense. I mean when you
first apply that he had to do a background check and they found hes got DV and alcoholic
problems. Well and then he told him, Well, I need him in my pocket so go ahead and issue
the license.719 KIM also questioned why the file disappeared720 and then may have been altered
when sent to DOJ for their investigation,721 characterizing these incidents as sinister722 and a
cover-up.723
714
Ex A1c, p 38
Ex A1c, p 38-42
716
Ex A1c, p 44-48
717
Ex. A1c, p.53
718
Ex A1c, p 60
719
Ex A1c, p 63
720
Ex A1c, p 63
721
Ex A1c, p. 69
722
Ex A1c, p 72
723
Ex A1c, p 75
715

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When asked about the allegations of GIUSTO misconduct relating to the restraining order, KIM
asserted that GIUSTO hung onto the Order and did not serve it when he should have. According
to KIM, JEDDELOH is now suing GIUSTO regarding this event.724
KIM identifies his number two source as a lieutenant725 and his number one and three sources as
sergeants, in the police discipline and both answering to the lieutenant.726
When asked about the allegation of GIUSTOs relationship with DOSS, KIM acknowledged that
he does not know DOSS or GIUSTO, but that when he posed the allegation in his letter, all he
was doing was raising enough question for you to investigate.727
When asked about the allegation of GIUSTO making false statements to the media and the
public about the nature of his relationship with DOSS, based on emails and insurance documents
that were copied on MCSO copy machine, KIM asserted that he learned this information from
the media but could find out who found the documents on the copy machine.728
When asked about the allegation about the sheriffs office losing public confidence, causing the
Board of Multnomah County Commissioners to inquire whether criminal conduct was involved,
KIM affirmed that he wanted DPSST to determine if GIUSTO had violated any administrative
rules regarding GIUSTOs ability to head his office.729
When asked what caused him to believe that the attorney generals investigation was tainted,
KIM referred to the media and stories that had been printed. KIM cited Arthur Sulzberger who
had been following GIUSTOs career and who does not see eye to eye with GIUSTO730 and
who has a hatchet to bury731 as having asserted the investigation was tainted. KIM referenced
DA Shrunks referral to the Attorney Generals office due to a conflict of interest.732 When
PARSONS explained the appropriateness of a referral, based on a potential conflict of interest,
and that it would not be under DPSSTs purview to investigate whether the Attorney Generals
Office was being influenced by the Democratic Party or the governor, KIM commented, Well
throw that one out.733
When asked about KIMs allegation of GIUSTO being sanctioned by the IACP for campaigning
on behalf of Kulongoski, KIM asserted that he had heard about this from his friend, the one who
was working for the Gresham Police Department at the time.734
724
Ex A1c, p 66
Ex A1c, p 74
726
Ex A1c, p 75-77
727
Ex A1c, p 80
728
Ex A1c, p 82
729
Ex A1c, p 84
730
Ex A1c, p 85
731
Ex A1c, p 90
732
Ex A1c, p 85
733
Ex A1c, p 90
734
Ex A1c, p 91
725

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When asked about KIMs allegation against GIUSTO regarding a report by the Multnomah
County District Attorneys office about sick leave and overtime, KIM asserted that he had heard
about this from his friend, whose information matched the medias reports.
When asked about KIMs allegation about arrests of GIUSTOs subordinates being a direct
result of GIUSTOs inability to address conduct that too closely mirrors his own, KIM identified
Deputy GREEN who contacted women to look at their tattoos, and Deputies WATSON and
WEISE who were arrested for engaging in sexual conduct with female inmates. KIM asserted
What theyre doing mirrors what hes doing. And what theyre saying is, Hey, how can you
judge me when youre doing the same thing?735
When asked about KIMs allegation about the public humiliation of the sheriffs office, KIM
referred to articles that the media had written. When asked if investigations should be launched
into public officials based on what the media reported, KIM stated, No.736
PARSONS asked KIM to contact his friends and others that he indicated he would contact
during the interview.
735
736
Ex A1c, p 96
Ex A1c, p 98

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58. Robert KIM - Interview #2 Questions

1. Have you spoken to your sources about coming forward?
2. If not, when will you speak with them
3. Identify opportunity that Lt. MCCAIN provided for confidentiality
59. Robert KIM #2 Interview Summary
On July 16, 2007, PARSONS and KING called KIM to follow up on KIMs sources. KIM stated
that his sources did not want to talk to investigators. PARSONS advised KIM that Lt. Bruce
MCCAIN, MCSO, had agreed not to see the identity of the sources unless and until such time
that a contested case hearing were to be held, and then as a part of discovery. KIM stated that
he would talk to his friends again. PARSONS confirmed that KIMs sources were police, not
corrections officers. PARSONS also advised that there may be enough identifiers to determine
who the sources were, at which point their anonymity could not be guaranteed. PARSONS
asked how KIM formatted his letter and he stated that he had looked at some forms and then
copied them as close as possible. KIM stated his friends helped him with the general report.
KING confirmed that if the sources did not come forward, DPSST would continue to look at the
identifiers to determine who they were. 737
60. Robert KIM - Interview #3 Questions
1. Have you spoken to your sources
2. If no, when will you speak to them
3. Identify discrepancies in allegations
61. Robert KIM #3 Interview Summary
On July 30, 2007, PARSONS and KING called KIM to follow up on KIMs sources. PARSONS
advised KIM of her concerns that there had been inaccuracies identified. PARSONS asked if
KIM had spoken to his sources to see if they would come forward. KIM stated that he had not
spoken with them, but would speak with them the following weekend.738
737
738
Ex A1d
Ex A1e

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62. MCSO Chief of Staff Christine KIRK Interview Questions

7. If so, how so
8. I understand you were involved in the intervention matter concerning GIUSTO and
JEDDELOH
command staff

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63. MCSO Chief of Staff Christine KIRK Interview Summary

On July 27, 2007, PARSONS and KING interviewed KIRK at her place of employment. The
purpose of the interview was fact finding to determine what first hand knowledge she had
regarding the intervention of JEDDELOH.
After reviewing her background KIRK characterized her relationship with GIUSTO as purely
professional. When asked what her role was, KIRK stated that her role was very limited, that
she had peripheral knowledge of the weapons permit and her role was to convey what was
occurring to Maggie MILLER, the director of the Crime Commission.
KIRK stated that at one point she did drive by the location of the intervention and she observed
ROSS and GATES outside and then GIUSTO and JEDDELOH come out of the building.
GIUSTO told KIRK that everything went well, he released GATES and ROSS and accompanied
JEDDELOH away from the area. When asked if she had any concerns with the manner that the
intervention was handled, KIRK stated that although GIUSTOs involvement could be
questioned, she thought GIUSTO balanced the politics and the ethics appropriately based on
what was occurring.
When asked if KIRK knew KIM, or anyone in MCSO who knew KIM, KIRK stated she did not.

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64. Governor Ted KULONGOSKI Interview Questions

Background
Governor KULONGOSKI was a common acquaintance of LEONHARDT and
GOLDSCHMIDT. According to LEONHARDT, he told KULONGOSKI he had learned of
GOLDSCHMIDTs crimes from GIUSTO prior to KULONGOSKIs higher education
appointment of GOLDSCHMIDT.
On July 12, 2007, LORANCE responded to a call from REESE to discuss the DPSST request to
speak to Governor KULONGOSKI as a part of the fact-finding into the GIUSTO
investigation.739
On August 16, 2007, KING and LORANCE met with REESE and SKYE, legal counsel for
Governor KULONGOSKI, at their request. KING and LORANCE responded to questions
regarding the matters within the scope of DPSSTs investigation and why it was believed that
KULONGOSKI might have information on knowledge that related to the investigation, as well
as general processes associated with DPSST denial and revocation cases. Also discussed were
the various blocks of time that KING or KULONGOSKI would not be available due to prior
commitments.
On August 20, 2007, DPSST received a letter requesting that DPSST pose its questions for
KULONGOSKI in writing so that he could provide a written response in order to work around
these schedules.740
On August 22, 2007, DPSST sent a letter to KULONGOSKI outlining the prior contacts and
including the questions.741 DPSST requested that the response be in the form of a notarized
affidavit.
739
Ex A63b
Ex A63a
741
Ex A63b and A63c
740

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65. Governor Ted KULONGOSKI Interview Summary

On September 5, 2007, DPSST received KULONGOSKIs 5-page response which was not in the
form of a notarized affidavit, nor signed by KULONGOSKI.742
KULONGOSKI affirmed he has known LEONHARDT for over twenty years and stated that
they were friends during the GOLDSCHMIDT administration but they have lost touch over the
years and have not spoken in the last five years. Prior to that time KULONGOSKI stated he
stopped by LEONHARDTs home occasionally over the course of approximately ten years and
he recalled going on walks with LEONHARDT and his child as well as socializing with
LEONHARDT in his home and at events such as sporting events and meeting for a beer.
KULONGOSKI does not recall Christy LEONARDT working as a county campaign coordinator
for him during his 1982 campaign for Governor.
KULONGOSKI denied LEONHARDT shared any information about GOLDSCHMIDT having
sexual intercourse with a minor female. KULONGOSKI denied telling LEONHARDT that it
might be true or words to that effect when LEONHARDT told KULONGOSKI about
GOLDSCHMIDTs relationship with a minor female.
KULONGOSKI denied telling LEONHARDT he learned of GIUSTOs affair with Margie
GOLDSCHMIDT around 1988.
KULONGOSKI denied telling LEONHARDT that GIUSTO might have had something on
Neil or words to that effect.
KULONGOSKI stated that he and his wife attended several holiday parties at
GOLDSCHMIDTs home, but does not ever recall traveling with LEONHARDT to those events.
KULONGOSKI denied LEONHARDT told him additional information he had learned from
GIUSTO regarding it being made public in the near future, financial issues relating to
GOLDSCHMIDT or subsequent telephone conversations with LEONHARDT about when the
information would come out in the media.
KULONGOSKI does not recall STONE or GIUSTO telling him anything about
GOLDSCHMIDTs sexual relationship with a minor female. KULONGOSKI affirmed that he
first learned about GOLDSCHMIDTs sexual relationship with a minor female the evening
before the story broke in the media when his chief of staff called him to let him know the story
would be in the paper the next day.743
KULONGOSKI declined to provide his answers in the form of an affidavit. KULONGOSKI did
provide an unsigned type-written response.744
742
Ex A63d
Ex A63d
744
Ex A63d
743

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66. Christy LEONHARDT Interview Questions

Background:
Christy is Freds wife, has first hand knowledge of attendance to several functions involving
GIUSTO and Margie, as well as KULONGOSKI.
1. When did you first meet Margie GOLDSCHMIDT
2. Describe the circumstances surrounding your first meeting with Margie
3. Describe your relationship with Margie, social, business, confidant (past and present)
4. When is the last time you spoke with Margie
5. How did you and Fred come to be invited to Margies 1994 party
6. Can you provide me with a copy of your daytimer that shows this invitation
7. When you were at Margies party, did you see Fred and KULONGOSKI there together
talking, where, (floor behind couch)
8. Could you hear what they were saying
9. Did Fred tell you later what they were talking about
10. When did you first learn about GOLDSCHMIDTs crime
11. Who did you learn this from
12. What specifically were you told
13. Identify source, etc
14. Get Affidavit from Christy, she corroborates Fred seeing Kul and Fred sitting on the
floor
15. Is there any reason that you can think of that Fred would identify GIUSTO as the
person who told him of GOLDSCHMIDTs crime, and why he would assert he had
told KANTOR and KULONGOSKI if it were not true?

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67. Christy LEONHARDT Interview Summary

On July 17, 2007, PARSONS and KING had a telephone conversation with Christy
LEONHARDT to determine what knowledge she had about her husbands interaction with
GIUSTO, GOLDSCHMIDT and KULONGOSKI.
LEONHARDT stated that she first met GIUSTO when he was a New Years Eve guest.
LEONHARDT stated she met Margie GOLDSCHMIDT around the same time at a staff function
at Mahonia Hall (the Governors residence).745 LEONHARDT stated the first time she saw
GIUSTO and Margie GOLDSCHMIDT together was at a Christmas function at Mahonia Hall in
1989 when she was wandering though the different floors and came to the ballroom where she
saw GIUSTO and Margie GOLDSCHMIDT dancing, alone. Later, after GOLDSCHMIDT left
office, GIUSTO and Margie GOLDSCHMIDT were openly a couple and GIUSTO was always
the co-host at Margie GOLDSCHMDITs home when Christy LEONHARDT and her husband
were invited as friends and neighbors of Margie GOLDSCHMIDT.746
LEONHARDT stated that her husband Fred LEONHARDT was Margie GOLDSCHMIDTs
confidant. LEONHARDT recalled the last time she spoke with Margie GOLDSCHMIDT was
last fall when Margie GOLDSCHMIDT called her home asking to speak with Fred
LEONHARDT and after answering the telephone she transferred it to her husband.747
LEONHARDT stated the last time they were together with GIUSTO and Margie
GOLDSCHMIDT was during a summer event when she and her husband Fred LEONHARDT
were invited over, along with Ted KULONGOSKI and his wife Mary.748
When asked if LEONHARDT had seen her husband and Ted KULONGOSKI sitting on the floor
behind a couch, LEONHARDT identified that event as a Christmas function at Margie
GOLDSCHMIDTs home where Fred LEONHARDT had been talking to GIUSTO about the
details of the financial arrangement. 749 LEONHARDT described the residence as small and that
the guest had limited seating. At that event, LEONHARDT stated that she and Mary OBERST
(Ted KULONGISKIs wife) were seated on the couch with a man by the name of Homer
WILLIAMS. LEONHARDT recalled seeing her husband, Fred LEONHARDT and Ted
KULONGOSKI seated on the floor behind the couch in a very intense conversation.
LEONHARDT stated she could not overhear their conversation because it was noisy, but that her
husband told her what it was about after the party.750
LEONHARDT stated that Fred LEONHARDT told her on the way home that all of a sudden he
had enough information about kind of the back dealings of the finances between Neil and --and this girl . . .that Fred was thinking there must be something to this story. He hadnt wanted
745
Ex A29d,p 3
Ex A29d, p 4
747
Ex A29d, p 5
748
Ex A29d, p 6
749
Ex A29d, p 7
750
Ex A29d, p 8
746

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to believe it until then.751 LEONHARDT stated that Fred LEONHARDT had been a believer
and follower of GOLDSCHMIDTs and that he had dismissed the stories he had heard. When
GIUSTO told LEONHARDT about Margie GOLDSCHMIDT agreeing to open her divorce
agreement with Neil GOLDSCHMIDT, to convince the lawyers that Neil GOLDSCHMIDT
didnt have enough money to pay off the girl, that really was the turning point.752
LEONHARDT stated from that point forward, Fred LEONHARDT made it clear that he wanted
to disassociate himself in every possible way from the former administration, he stopped going
to the reunion parties, he wouldnt accept any more work related to GOLDSCHMIDTs
business.753
When asked how long the conversation lasted between KULONGOSI and LEONHARDT
behind the couch, Christy LEONHARDT stated about twenty minutes or so. When asked to
identify others that were present at the party, LEONHARDT stated she was terrible at names and
attempted to recall a number of the guests.754
When asked when Christy LEONHARDT first learned about GOLDSCHMIDTs crime, she
stated that Fred LEONHARDT told her the day that GIUSTO told him. LEONHARDT stated
that it was in the fall after a trip to Salem where they had breakfast together.755
LEONHARDT stated that when she heard, she knew Neil GOLDSCHMIDT had a reputation
of liking women and she was probably like so many other people thinking more about
GOLDSCHMIDT than about the victim.756
LEONHARDT stated her husband, Fred, had told her about rumors that one of the reasons that
GOLDSCHMIDT decided not to go for a second term was the opposition had information about
his involvement with other women. LEONHARDT stated that over the years she became tired
of Fred harping on the issue of GOLDSCHMIDT and wanted him to put it behind him but then
she realized the kind of person that she was married to had such a strong sense of integrity and
justice that it angered him that nobody was listeningthat nobody cared. LEONHARDT
stated that she then came to respect the fact that her husband, Fred, had really suffered personally
and professionally for taking his stand, because he has daughters he has a sense of what is right
and wrong for your children and daughters and she is intensely proud of that.757
LEONHARDT stated that she and her husband Fred have very few friends left; that it has been a
test of their whole relationship with people that they were formerly extremely close to and that
they were talking about having Ted KULONGOSKI and Mary be the godparents of their
children at one point.
LEONHARDT stated that she first met Ted KULONGOSKI when she was his campaign
manager for Yamhill County, and that she had known him for a long time. LEONHARDT stated
751
Ex A29d, p 9
Ex A29d, p 10
753
Ex A29d, p 10
754
Ex A29d, p 11 -13
755
Ex A29d, p 15
756
Ex A29d, p 15-16
757
Ex A29d, p. 16-17
752

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at some point KULONGOSKI made a decision what was important to him and unfortunately
they fell on different sides of the decision.758
LEONHARDT stated that she was KULONGOSKIs campaign manager the first time he ran for
governor when he lost. LEONHARDT stated that it was Neil GOLDSCHMIDT who brought
him back in to political life when he appointed KULONGOSKI as the insurance commissioner.
It was after that when KULONGOSKI decided to run for attorney general, which then put him a
position to run for governor.759 LEONHARDT stated that KULONGOSKI has had a burning
desire to serve and when Fred came up with this inconvenient story and experience, exposing
distasteful knowledge, it didnt fit with [KULONGOSKIs] agenda.760
When asked what LEONHARDT recalled about what her husband, Fred, told her regarding
GIUSTOs disclosures, she stated GIUSTO had said when Neil GOLDSCHMIDT was the
Mayor he had a sexual relationship with an underage girl. The mother of the girl was active in
politics.761 LEONHARDT could not recall if the name came up then or later. When asked what
Fred LEONHARDT did with the information, Christy LEONHARDT stated that Fred
LEONHARDT went to Gregg, [KANTOR] his supervisor.762 KANTOR then returned to Fred
LEONHARDT and stated, you dont want to know. Christy LEONHARDT stated that Fred
LEONHARDT was new to the job, and that he was totally devoted to his job and to Neil
GOLDSCHMIDT.763 Christy LEONHARDT related a number of examples of Fred
LEONHARDTs efforts toward the job and his long hours.
Christy LEONHARDT stated Fred LEONHARDT fought the reality of what he had learned for
years, until the night GIUSTO talked about lawyers.764
Christy LEONHARDT stated that when GIUSTO asserted in a talk radio show that he doesnt
even know Fred LEONHARDTs name he was lying, and in other documented instances he was
also lying in public and that testifies to GIUSTOs character.765
KING reviewed the process for Christy LEONHARDT to review her affidavit which would be
prepared from the telephone interview. KING obtained general background information on
Christy LEONHARDT for the affidavit.
Christy LEONHARDT signed an Affidavit attesting to her assertions.766
758
Ex A29d, p 18
Ex A29d, p 19
760
Ex A29d, p 20
761
Ex A29d p. 20
762
Ex A29d, p 21
763
Ex A29d, p 22
764
Ex A29d, p234
765
Ex A29d, p 25
766
Ex A29g
759

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68. Fred LEONHARDT Interview Questions

Background:
LEONHARDT has first hand knowledge of GOLDSCHMIDT administration. Was told by
GIUSTO of GOLDSCHMIDTs crime, he alleges he told KULONGOSKI and KANTOR.
1. How long were you a speechwriter for GOLDSCHMIDT; was it for the entire term or
a portion of it?
2. How did GOLDSCHMIDT leave office, voted out?
3. What was the name of the Dakota Bars co-owner who identified victim after meeting
with GOLDSCHMIDT?
4. When GIUSTO offered to give you a ride, was this common practice or was it out of
the blue?
5. Regarding GIUSTOs offer to drive you to Salem, what was the proximity between
your residence and GIUSTOs?
6. Had GIUSTO ever offered to drive you to work prior to this, or after?
7. Had you ever offered to drive GIUSTO to work prior to this, or after?
8. Who was the top GOLDSCHMIDT official that you told about crime and that you had
learned the information from GIUSTO?
9. Who else did you discuss this info with in the office?
10. Do you have corroborating evidence that you and GIUSTO socialized, pictures, events,
etc?
11. Do you have corroborating evidence that you and KULONGOSKI socialized, pictures,
events, etc?
12. Need a copy of Christys day planner of Dec 2, 1994 holiday party
13. Have you ever met Pam Dunham
15. Describe your relationship with Pam Dunham
16. Where did Pam Dunham work, was it in state government?
17. If so, did she work in the GOLDSCHMIDT administration
19. Specifics versus vague, all around 1989 when settlement occurred
20. Who was the long time GOLDSCHMIDT associate who brokered the cash payments,
according to GIUSTO

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69. Fred LEONHARDT Interview Summary

On June 19, 2007, PARSONS and KING met with Fred LEONHARDT at his residence for the
purpose of following up on the letter he wrote to DPSST in which he cited complaints about
Sheriff Bernard GIUSTO. LEONHARDT was asked to provide investigators with back ground
on how he knew the individuals that he cited in his letter, i.e., KULONGOSKI, GIUSTO and the
GOLDSCHMIDTS.
LEONHARDT stated that he has known Ted KULONGOSKI since he ran for Governor in
1982767 and characterized his relationship with KULONGOSKI as friends of friends, and they
ran into each other occasionally. LEONHARDT stated that he and KULONGOSKI would see
one another outside of work when they would stop for drinks at a bar.768
LEONHARDT stated he had been a speechwriter for Neil GOLDSCHMIDT starting in 1987.
LEONHARDT stated he used KULONGOSKI as a reference for this position.769
LEONHARDT stated that when he was GOLDSCHMIDTs speech writer, he met GIUSTO,
who was the head of security. LEONHARDT stated he enjoyed hanging out with GIUSTO.
LEONHARDT stated GIUSTO traveled with the governor and would report back to
LEONHARDT on how the speeches he had written for GOLDSCHMIDT had been received.
LEONHARDT stated that the relationship with GIUSTO grew over the years, as it did with
KULONGOSKI.770
LEONHARDT stated that he would organize get-togethers at the old Dakota Caf after work for
staff members and that at these events GIUSTO and Margie GOLDSCHMIDT were dance
partners.771 LEONHARDT also recalled a time when Margie GOLDSCHMIDT and GIUSTO
arrived at a Halloween party dressed in matching outfits.
LEONHARDT recalled a time when a news reporter observed GIUSTO and Margie
GOLDSCHMIDT together at the Dakota and asked LEONHARDT and other staff members how
long they had been having an affair.772
When asked what prompted GIUSTO to tell him about Neil GOLDSCHMIDTs relationship
with the underage female, LEONHARDT stated he did not know, that it was a mystery to him.
LEONHARDT stated when he discussed GIUSTOs assertions about Neil GOLDSCHMIDT
with Gregg KANTOR, together they decided GIUSTO must have been jealous of Neil
GOLDSCHMIDT or that GOLDSCHMIDT had done something to humiliate GIUSTO.
767
Ex A15f, p3
Ex A15f, p 4
769
Ex A15f, p3
770
Ex A15f, p 4
771
Ex A15f, p 6
772
Ex A15F, P 6
768

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LEONHARDT stated that after he told KANTOR what GIUSTO had told him, he expected that
GIUSTO would have been questioned. LEONHARDT stated that GIUSTO had made comments
in the past about Neil GOLDSCHMIDT and Ruth Ann DODSON inferring something more than
a professional relationship but that there had been no indication GIUSTO was going to divulge
the information about Neil GOLDSCHMIDT and the underage female.773
LEONHARDT stated that he learned later that GIUSTO had also told the same story to Debby
(Kennedy) STONE around the same time that he had told LEONHARDT. LEONHARDT stated
that STONE had called him after his story broke in 2004 and told him of her knowledge.774
LEONHARDT also indicated that STONE had shared some of this information with the media.
LEONHARDT stated that he considered KANTOR his best friend in the office, even though
KANTOR was his supervisor. LEONHARDT stated that KANTOR told him that he was going
to share the information with Tom IMESON, GOLDSCHMIDTs chief of staff. LEONHARDT
asserted that KANTOR returned to him and told him that Toms going to look into it. Then,
by the end of that day, KANTOR stated to him, You dont want to know about it.
LEONHARDT stated he did not speak with IMESON about the matter at the time, but did run
into him in 2005, at which time IMESON stated KANTOR never came to him with the GIUSTO
information. IMESON pointed to the fact that Neil GOLDSCHMIDT was threatening to drop
out of the re-election campaign and he was trying to convince him to stay in; he would never had
done this if he had known what GIUSTO was asserting.775
LEONHARDT stated that Ruth Ann DODSON worked closely with Neil GOLDSCHMIDT,
scheduled his appointments, and had worked with him since he was the mayor of Portland.
LEONHARDT speculated that KANTOR may have gone to DODSON rather than IMESON
with GIUSTOs information. LEONHARDT stated that according to one media source,
DODSON had actually taken calls from GOLDSCHMIDTs victim at the governors office.776
LEONHARDT stated that KANTOR spent a lot of time trying to convince him that GIUSTOs
story was absurd and because Neil GOLDSCHMIDT was his political hero, LEONHARDT did
not want to believe GOLDSCHMIDT was a child molester. LEONHARDT stated that
KANTOR said he does remember being told about the GIUSTO story, but does not recall telling
LEONHARDT that he went to IMESON.777
LEONHARDT stated that he understood that DODSON took calls from the victim, knew the
victims mother, and had worked with the victims mother, but that she did not tell her husband
MARK DODSON, or Neil GOLDSCHMIDT, which LEONHARDT found absurd.
LEONHARDT said Ruth Ann DODSON may have been the go-between between the victim
and Neil GOLDSCHMIDT, according to GIUSTO. LEONHARDT stated that everything that he
had learned from GIUSTO regarding the victims name, age, her mothers identity, the
773
Ex A15f, p 8
Ex A15f, p 10
775
Ex A15f, p 12
776
Ex A15f, p 13
777
Ex A15f, p 14
774

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relationship with Neil GOLDSCHMIDT and where the victim lived, he later found to be
accurate information.778
When asked what LEONHARDT interpreted KANTORs comment, You dont want to know
about it, to mean, LEONHARDT stated he and KANTOR talked about that comment for weeks
and what it could have meant.779
LEONHARDT stated that when IMESON told him that KANTOR had not come to him, he
believed him because having that information would have precluded IMESON from later going
into business with GOLDSCHMIDT.780
When asked to provide specifics about his breakfast with GIUSTO, LEONHARDT stated that
GIUSTO identified the victim as Elizabeth Dunham, stated she was 14 years old at the time of
the misconduct or crime, that she was a babysitter, that the victims mothers name was Pam
Dunham, and that he recalled recognizing the mothers name because of her visits to the office
and because of the position she held. Also, LEONHARDT stated that he recalled that the mother
had quit her job and left the state.781
LEONHARDT stated that as time went on he began to believe the possibility that what GIUSTO
had told him might be true. He thought maybe Neil GOLDSCHMIDT got drunk and did a
horrible thing that he had regretted. Then LEONHARDT learned that the abuse of the victim
had gone on for three years. LEONHARDT stated that GIUSTO did not tell him of the duration
of the abuse.782
When asked what GIUSTO told him about Neil GOLDSCHMIDTs misconduct with the victim,
he stated that GIUSTO told him that Neil GOLDSCHMIDT raped the victim.
LEONHARDT stated that according to GIUSTO, one of Margie GOLDSCHMIDTs brothers
was told about the abuse by the victims mother and that he contacted Neil GOLDSCHMIDT
and told him that either he had to tell Margie GOLDSCHMIDT or that he would tell his sister.
According to GIUSTO, Neil GOLDSCHMIDT confessed to Margie GOLDSCHMIDT.
LEONHARDT stated that he has spoken with Margie GOLDSCHMIDT about the abuse and that
Margie GOLDSCHMIDT characterized it as the underage girl being a sexual predator who
trapped poor dumb Neil.783 LEONHARDT speculated that Margie GOLDSCHMIDT possibly
found out about Neil GOLDSCHMIDTs crime around 1988 because that was when she stopped
coming into the office and going on staff retreats, and was depressed. LEONHARDT also
speculated that GIUSTO and Margie GOLDSCHMIDT may have been seeing one another by
then; LEONHARDT recalled GIUSTO telling a media source that his affair with Margie
GOLDSCHMIDT began in 1986 or 1987.784 LEONHARDT confirmed that he personally spoke
778
Ex A15f, p 15
Ex A15f, p 16
780
Ex A15f, p 17
781
Ex A15f, p 18
782
Ex A15f, p 19
783
Ex A15f, p 20
784
Ex A15f, p 21
779

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with Margie GOLDSCHMIDT at lunch in 2004, after the story broke.785 Although they did not
discuss the issue during lunch, after lunch Margie GOLDSCHMIDT called LEONHARDT and
stated that someone close to Neil GOLDSCHMIDT told her that LEONHARDT was wearing a
wire, and was going to record their conversation over lunch.786 She decided this wasnt true
when LEONHARDT did not bring up the issue. When LEONHARDT told Margie
GOLDSCHMIDT that GIUSTO had told him about Neil GOLDSCHMIDTs crime in 1989,
LEONHARDT stated that Margie GOLDSCHMIDT was pretty stunned. LEONHARDT
states that Margie GOLDSCHMIDT first denied it but then asserted that the victim was a sexual
predator when LEONHARDT provided details that GIUSTO had provided to him.787
LEONHARDT stated that in the spring, prior to GIUSTO telling him the story about Neil
GOLDSCHMIDT in the fall, he, KANTOR, Neil GOLDSCHMIDT and GIUSTO were sitting in
the DAKOTA Caf when a young woman approached their table, stared at Neil
GOLDSCHMIDT and when Neil GOLDSCHMIDT pulled out a green schedule card and looked
at it, he asked the woman, Are you on my schedule for tomorrow? The woman nodded and
left. Shortly thereafter, LEONHARDT was in the Dakota Caf again, saw the same woman at
the bar, recognized the woman as the one from the previous encounter and asked the owner who
she was. The owner identified the woman as Elizabeth Dunham. Because the caf owner told
LEONHARDT she was bad news, and he took note of this because he knew the caf owner to
be pretty lenient about things. Then, later when GIUSTO provided the name to
LEONHARDT, he stated that he recognized her name.788
When asked about the babysitter, LEONHARDT stated that although GIUSTO had told him
that the victim was a babysitter, Margie GOLDSCHMIDT had denied that she was a babysitter
for them.789 LEONHARDT stated that the victim and her mother were neighbors of Margie and
Neil GOLDSCHMIDT. Additionally, LEONHARDT stated that the victims mother worked for
Neil GOLDSCHMIDT on his campaigns.790
LEONHARDT affirmed that he had learned from Ted KULONGOSKI that after Neil
GOLDSCHMIDT learned of GIUSTOs affair with Margie GOLDSCHMIDT, he continued to
retain GIUSTO as a driver and also had him promoted. LEONHARDT stated that IMESON told
him that he felt they had been tricked into the promotion by GIUSTO because GIUSTO told
them that every head of the governors security detail was a lieutenant or promoted to lieutenant.
LEONHARDT stated that he thinks IMESON later found that GIUSTOs assertion was not
true.791 LEONHARDT stated that he does not know what role Neil GOLDSCHMIDT played in
the promotion of GIUSTO to lieutenant.792
When asked when he last had contact with GIUSTO, LEONHARDT stated it was at the
Governors Inaugural in 2003 where they sat next to one another in the ceremonial office.
785
Ex A15f, p 22
Ex A15f, p 23
787
Ex. A15f, p 24
788
Ex A15f, p 25
789
Ex A15f, p 26
790
Ex A15f, p 27
791
Ex A15f, p 28
792
Ex A15f, p 29
786

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LEONHARDT stated that GIUSTO asked him to call him. Prior to that, LEONHARDT stated
that they had seen one another many times over the years at parties at Margie
GOLDSCHMIDTs home. One such example was during the summer of 2001 when Margie
GOLDSCHMIDT invited LEONHARDT and his wife and Ted KULONGOSKI and his wife to a
barbeque. Another example of them socializing was in the 1990s when GIUSTO and Margie
GOLDSCHMIDT stopped by LEONHARDTs residence unannounced after attending a
fundraiser.793
LEONHARDT said its Margie and me, not Margie and his wife, who were friends. Margie
GOLDSCHMIDT was very emotional about LEONHARDT remaining friends with GIUSTO
because GIUSTO didnt have many friends. At one point Margie GOLDSCHMIDT showed up
in LEONHARDTs office crying because he wasnt talking to GIUSTO anymore.794
LEONHARDT stated that when GIUSTO referred to him as, Mr. Leonhardt, whoever he is, or
I havent spoken to him in 15 years, these were false statements by GUISTO.795
LEONHARDT stated that GIUSTO denied to the media any knowledge of Neil
GOLDSCHMIDTs crime until one of the medias top investigative reporters planted himself in
Bernies office, refused to leave and then GIUSTO finally admitted he may have heard a rumor
to that effect, that he may have told LEONHARDT, and that he may have had a discussion in
vague general terms. LEONHARDT asserted that GIUSTO was untruthful when he told the
media that I never told him anything in great detail.796
LEONHARDT recalled another incident when GIUSTO spoke to a media source. This source
asked GIUSTO, Is it true, what LEONHARDT is asserting? GIUSTO said no. When the
source asked, Did you tell LEONHARDT? GIUSTO said, No, not in any great detail. This
shocked LEONHARDT.
When asked if LEONHARDT had heard the victims name from anyone other than GIUSTO,
LEONHARDT stated his only source was GIUSTO until the story broke in the media.
LEONHARDT then confirmed that he heard the victims name from GIUSTO when he first told
him in 1989, from the bartender of the caf during that same time frame, and then in 1994 when
LEONHARDT asked additional questions of GIUSTO.797
LEONHARDT stated that he and his wife, and Ted KULONGOSKI and his wife went together
to the party at Margie GOLDSCHMIDTs residence which GIUSTO also attended. This was a
holiday party in 1994. LEONHARDT stated that in 1991 or 1992, he and Ted KULONGOSKI
discussed why Neil GOLDSCHMIDT would have kept GIUSTO on the security detail, unless
GIUSTO had something on Neil GOLDSCHMIDT. LEONHARDT stated he told Ted
KULONGOSKI that he was going to ask GIUSTO for more details at the [1994] party.
LEONHARDT stated that he did speak with GIUSTO at the party and after referencing what
793
Ex A15f, p 30
Ex A15f, p 31
795
Ax A15f, p 32
796
Ex A15f, p 33
797
Ex A15f, p 34
794

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GIUSTO had told him in 1989, asked what the upshot was. According to LEONHARDT,
GIUSTO began to tell him that the story would be in the media any day, that the victim had
gotten a lawyer, that the victim was threatening a lawsuit and that they were in negotiations.798
GIUSTO further stated that Diana GOLDSCHMIDT had just found out and GIUSTO knew this
because Neil GOLDSCHMIDT had called Margie GOLDSCHMIDT for permission to open
their sealed divorce records to show prior financial commitments. LEONHARDT stated that he
immediately found Ted KULONGOSKI and dragged him into a corner where they could talk,
where he told him everything he had just learned from GIUSTO. LEONHARDT stated that for
the next days, or weeks, he and Ted KULONGOSKI were on the telephone because they had
been looking for the article to come out. LEONHARDT asked Ted KULONGOSKI if he had
shared the information with his wife, Mary. According to LEONHARDT, Ted KULONGOSKI
stated that Mary credited Neil GOLDSCHMIDT with resuscitating KULONGOSKIs career
when GOLDSCHMIDT appointed him to insurance commissioner, therefore he did not want to
tell her about it.799
LEONHARDT stated that at some later point he asked GIUSTO why the news article had not
come out and GIUSTO stated that there was a confidentiality agreement and a cash settlement.
At that point LEONHARDT stated he began to remove himself further from Neil
GOLDSCHMIDTs circle and that was when he decided that if Neil GOLDSCHMIDT ever
tried to run for office, or was appointed to office, he would go to the media. When
LEONHARDT learned that Ted KULONGOSKI was appointing [Neil GOLDSCHMIDT] to the
State Board of Higher Ed, he did go to [the Oregonian] with his story.800
LEONHARDT stated that the Oregonian did not run the story, but as soon as the Willamette
Week ran the story, the Oregonian became re-interested in his story. LEONHARDT believed
that the Willamette Week had gotten their information from a completely different source.801
LEONHARDT speculated on why the Oregonian had not printed the story, and that the
information on Neil GOLDSCHMIDT was available, thereby creating huge red flags.
LEONHARDT stated that the week that the story did break he had breakfast with Ginny
BURDICK who wanted him to meet a contact of hers, Brian GARD.802
LEONHARDT stated that when he told Ginny BURDICK that he had learned information about
Neil GOLDSCHMIDT that kept him away, Ginny BURDICK first asked, What information
and then stated, I think I know. . . underage girl? Apparently someone from the media had just
contacted her to see if she knew anything because she had been Neil GOLDSCHMIDTs press
secretary during the 1986 campaign. LEONHARDT stated that it was Gard and Gerber [a public
relations firm] that was writing Neil GOLDSCHMIDTs confession and they decided to go to
the Oregonian, rather than to the Willamette Week because they would get better treatment. It
was after this conversation with BURDICK that LEONHARDT emailed Oregonian reporter Jeff
798
Ex A15f, p 36
Ex A15f, p 37
800
Ex A15f, p 39
801
Ex A15f, p 40
802
Ex A15f, p 41
799

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MAPES about the Willamette Week story and it was then that the Oregonian showed interest in
the story. 803
LEONHARDT stated that his interest was in keeping Neil GOLDSCHMIDT out of public life
and to do so, he had to reveal his source, which was GIUSTO. LEONHARDT stated that after
the story broke in the media, GIUSTO and Ted KULONGOSKI and a number of other
colleagues lied about their knowledge of Neil GOLDSCHMIDTs crime. LEONHARDT stated
that had they only finessed the truth, he would never have come forward but they flatly denied
any knowledge whatsoever.804
LEONHARDT stated that he and his wife socialized with GIUSTO and Margie
GOLDSCHMIDT to the extent that they were at the same parties, and although Margie
GOLDSCHMIDT talked about them getting together as a foursome, they never did.
LEONHARDT stated that he had remained friends with Margie GOLDSCHMIDT after she and
GIUSTO were no longer seeing one another she shared with him her feelings about when she
and GIUSTO broke up. However LEONHARDT said he and Margie GOLDSCHMIDT have not
continued to remain friends.
When asked if LEONHARDT knew of any other victims of Neil GOLDSCHMIDT, he stated
that reporters asked him for the names of his colleagues in the Governors office who had
daughters and understood there was another victim but that she did not want to go on the record
so the story was dropped.805
LEONHARDT stated that the Oregonian had dropped the story after writing an editorial that Ted
KULONGOSKI needed to answer hard questions in a public forum, and it was only after
LEONHARDT wrote a letter to the editor of the paper that reporter Alex POLASKI met with
him and asked him about various other rumors, all of which he knew nothing about.806 Later,
LEONHARDT stated that reporter Harry ESTEVE contacted him with follow up information on
additional rumors, which LEONHARDT knew nothing about.807
When asked about LEONHARDTs conversations with Ted KULONGOSKI, LEONHARDT
stated that in late 1991 or early 1992, when KULONGOSKI was first talking about running for
Attorney General, he told Ted KULONGOSKI what GIUSTO had told him about Neil
GOLDSCHMDIT and they decided he shouldnt become too closely connected with Neil
GOLDSCHMIDT, yet Neil GOLDSCHMIDT was involved in raising money for the
campaign.808
LEONHARDT stated that he has been labeled as KULONGOSKIs disgruntled ex-confidant by
the KULONGOSKI people who asserted that he was disgruntled because he had been fired from
the campaign, when in fact he had not worked for or in the campaign. LEONHARDT asserted
803
Ex A15f, p 43
Ex A15f, p 44
805
Ex A15f, p 46
806
Ex A15f, p 47
807
Ex A15f, p 48
808
Ex A15f, p 49
804

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that Ted KULONGOSKI told a reporter that he and LEONHARDT had lost most contact after
1996, which LEONHARDT characterized as an even bigger lie than Bernie. 809 When asked
if he knows what the relationship is now between Ted KULONGOSKI and GIUSTO,
LEONHART did not know.
When asked what he knew about Tom GIUSTO, LEONHARDT stated that he received a
telephone message from someone identifying himself as GIUSTOs brother, Tom.
LEONHARDT stated that he then returned the call, expecting to hear Tom GIUSTO telling him
to get off my brothers back but instead he wanted to apologize for not having backed me up
in 04. LEONHARDT stated that Tom GIUSTO stated he had known about GIUSTOs affair
with Margie GOLDSCHMIDT and that GIUSTO had known about the 14-year old.
Additionally, Tom GIUSTO told LEONHARDT that GIUSTO bragged that he had this hammer
over Neil . . . so he could do the governors wife. Tom GIUSTO was upset about GIUSTOs
womanizing. LEONHARDT stated that he immediately called reporter Harry ESTEVE who
stated to LEONHARDT that he had called Tom GIUSTO but Tom GIUSTO did not want to go
on the record by himself and he was going to try to talk to his sources in the Gresham Police
Department.
LEONHARDT stated that Tom GIUSTO later called him and left a message stating that he was
going to run for Gresham City Council and wanted LEONHARDT to help him on his campaign.
LEONHARDT found this bizarre and he didnt call him back.810 When asked if the individual
identifying himself as Tom GIUSTO provided him any information that would confirm that he
was Bernard GIUSTOs brother, LEONHARDT said no, but the caller expressed embarrassment
about Bernard GIUSTOs conduct, that he was angry, and that at one point in the conversation he
told LEONHARDT, I dont know why Im doing this.this isnt a trap..I dont know what
my motives are in calling you.811
LEONHARDT asked a number of process questions of PARSONS and KING relating to the
statute of limitations, mandatory reporting and provided contact information.
End of Interview.
Subsequent to this interview, Fred LEONHARDT signed an Affidavit attesting to his

assertions.812
Also, Fred LEONHARDT took a polygraph based on his sworn affidavit, asserting it was true
and accurate. Polygraph examiner YORK formed the conclusion that It is my opinion that the
physiological responses recorded during the polygraph examination, in reference to the relevant
questions, are consistent with the usual indications of truthfulness.813
809
Ex A15f, p 50
Ex A15f, p 52
811
Ex A15f, p. 53
812
Ex A15m
813
Ex A30c
810

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70. Jeff MAPES, Oregonian

contact us.
On June 13, 2007, Brent Walth and Jeff Mapes of The Oregonian reported, Giusto told the
Oregonian that he doesnt remember talking specifics with Leonhardt but may have discussed
vague rumors in 1989 . . .814
1.
2.
3.
4.
5.
6.
7.
8.

Confirm the author
Determine if the author is the individual who interviewed Giusto, if not who was
and if retained
9.
814
Ex A12.99

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MCSO Lt. Bruce MCCAIN (Chronological emails, see Ex A27)
Background:
Lt. Bruce MCCAIN is the administrative lieutenant for Bernard GIUSTO. MCCAIN has been
designated by GIUSTO as the point of contact for the investigative team to coordinate interviews
and questions regarding SOP and policies.
As of Saturday, October 20, 2007, MCCAIN now represents GIUSTO as his attorney.815
71. MCSO Lt. Bruce MCCAIN Conversation Summary
On June 28, 2007, KING had a telephone conversation with MCCAIN requesting documents for
the investigation. KING also explained that complainant Robert KIM had asserted there were
three individuals within MCSO who were his sources and he had provided some identifiers.
KING related KIMs assertion that the MCSO sources were fearful of retaliation. MCCAIN
assured KING that for that reason, GIUSTO had not launched an internal investigation and did
not want to make matters worse by making it look like retaliation.816
MCCAIN stated he thought the information was coming from the law enforcement side, rather
than the corrections side, because of the incidents relating to law enforcement personnel.
MCCAIN also stated that KIMs allegations looked similar to allegations made a year prior on a
complaint that was circulated at the Hansen Building (the law enforcement building).817
KING stated that she would give KIM another chance to produce his sources and if he did not,
she may review the identifiers with MCCAIN to determine who the sources may be.818
MCCAIN stated it was important for KIM to know that [he or GIUSTO] had made no ex-parte
communications with KIM or DPSST; that they would not interfere with the investigation.
MCCAIN also stated that GIUSTO was willing to allow KIMs sources to remain anonymous at
the staff level, but at the point that GIUSTO needed to defend himself during a contested case
hearing, the sources must be identified and put under oath.
End of conversation
815
Ex A27kk
Ex. A26a, p 4
817
Ex A26a, p 5
818
Ex A26a, p 6
816

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72. MCSO Civilian Deirdre McGILL Interview Questions

Background
McGILL is a civilian who has worked in both corrections and the law enforcement side of
MCSO. McGILL was the subject of GIUSTOs communications which resulted in MCSO HR
becoming involved.
7. If so, how so
8. Do you recall a time that you received a communication from GIUSTO that was not
specifically work related
9. If so, when did you receive it
10. If so, describe it; was via phone, email or other method
11. Did you receive more than one communication from GIUSTO that was not work
related
12. Do you still have a copy of this/these communication(s)
13. At some point did another individual become aware that you had received
communication(s) from GIUSTO
14. If so, how did this occur
15. Who was/were the others
16. Did you discuss the communication(s) with another person
17. If so, who did you discuss it/them with
19. Were you offended by GIUSTOs communications with you
20. If so, how were you offended
21. If not, did you have any concerns
22. If so, what concerns did you have
23. At some point did someone contact you about GIUSTOs communications with you
24. If so, who was that person
26. At some point did Jennifer OTT contact you
27. If so, what was your understanding of her organizational position in the agency
28. If so, what did you and OTT discuss
29. At any point did OTT, or any other individual tell you, or infer to you that if you
divulged GIUSTOs communication with you, your job would some how be in
jeopardy?
31. Do you feel that this matter has been resolved to your satisfaction?

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Investigation #2
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73. MCSO Civilian Deirdre McGILL Interview Summary

On July 26, 2007, PARSONS and KING met with McGILL at her place of employment to
determine what knowledge she had of the KIM allegation that GIUSTO had inappropriate
communications with a subordinate.
After a review of McGILLs employment background, when asked when she first met GIUSTO,
McGILL stated it was within the first couple weeks of his becoming the sheriff. McGILL stated
that she had approached him about the civilian uniforms and after that, GIUSTO stopped by her
work area to visit with her. McGILL stated that because she is friendly she would speak with
GIUSTO, although she was teased by her co-workers.819
McGILL stated that she was talking about her dog and that she was going to the beach for the
weekend, and that she had a pasta dish she wanted to make; that she was looking forward to
relaxing. McGILL stated the next day GIUSTO showed up with two bottles of wine and it kind
of freaked me out, and I went up to the guys and Im like, huh, I didnt know what to make of
it.820 McGILL stated she gave the wine to the members of the SIU unit.
McGILL stated she then received a call. Although it was garbled, she thought she recognized the
voice so she called the cell phone number back and got GIUSTOs voicemail. McGILL
wondered where GIUSTO got her personal cell phone number from. McGILL stated that she
recorded GIUSTOs message which was that he didnt know if McGILL was taking about the
beach house because it was an invitation to join her or what it was, and GIUSTO asked McGILL
to call her and let him know. McGILL stated that she shared the information with the SIU
officers and told them Im not comfortable with this, but let me handle it . . . I need to have
control . . . .I need to take care of this on my own.821 McGILL stated that the SIU officers
agreed; and then a couple of weeks later she received a telephone call from HR OTT saying she
wanted to visit with McGILL. McGILL described herself as livid that one of her co-workers
had gone to command staff. McGILL identified the co-worker as Sean CHRISTIAN and stated
that there have been several confrontations between them because of CHRISTIANs actions.
McGILL stated OTT did speak with her and made sure she did not want to file a complaint
against GIUSTO. McGILL stated that after this it was awkward with GIUSTO, and that at one
point she felt that GIUSTO was putting me in my place during a large meeting when she asked
a question.822 McGILL stated she is still teased by employees but that it would not have gotten
to that point if she would have been allowed to fix it myself.
When asked if McGILL thought that the situation had been resolved to her satisfaction as best as
it could be since someone else handled the situation and she affirmed the situation had been
handled, but that it should not have gotten to that point.
819
Ex A43a, p 3-4
Ex A43a, p 5
821
Ex A43a, p 6
822
Ex A43a, p 9
820

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When asked what OTTs demeanor was like, McGILL stated that, despite what the Mr. KIM
letter said, it was not threatening.823 When asked if OTT presented options of taking the matter
forward, McGILL stated that she thought it had been handled. When asked if McGILL felt OTT
threatened her in any way, McGILL she had not and affirmed OTTs contact was professional;
that the situation had been handled appropriately.824
When asked if she had any idea who may have said, or told KIM misleading information,
McGILL stated that because CHRISTIAN agrees to one thing behind closed doors and then does
another, he would be the main person I would think would have done that. McGILL stated
that it is her belief that CHRISTIAN plays games with people and she does not trust him.825
When asked if she had spoken with CHRISTIAN about OTT visiting her, McGILL stated that
they all had seen OTT come to visit with her so afterwards she told them that someone had gone
to the sheriff about her concerns and that all of the SIU members denied it. Later CHRISTIAN
admitted it was he who had gone to the sheriff.826
When asked when the incident with GIUSTO occurred, McGILL stated about three years ago.
When asked what her relationship was now with GIUSTO, McGILL stated although they do not
stop and talk, they now greet one another.827
When asked about emails between GIUSTO and herself, McGILL stated that they had emailed
but that it was not of a personal nature.828 McGILL stated that she respects GIUSTOs position
as sheriff.829 McGILL stated she does not know KIM, but her guess would be that his source
would either be Sean CHRISTIAN or someone in detectives.
823
Ex A43a, p 10
Ex A43a, p 11
825
Ex A43a, p 12
826
Ex A43a, p 13
827
Ex A43a, p 17
828
Ex A43a, p 18-19
829
Ex A43a, p 19
824

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74. Jacquenette McINTIRE Interview Questions

Background
In his complaint, KIM alleges that GIUSTO had a personal relationship with a female city
councilwoman. In his interview, GRAHAM identified the woman as MCINTIRE. The sole
focus is whether GIUSTO had any personal gain from this relationship.
1.
2.
3.
4.
5.
6.

7. If so, what
8. If not, why not
things

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75. Jacquenette McINTIRE Interview Summary

On August 6, 2007, PARSONS conducted a telephone interview of McINTIRE for the purpose
of determining if GIUSTO had any personal gain, as the Gresham Police Chief, from McINTIRE
who was on the Gresham City Council.
When asked if GIUSTO had any personal gain from his relationship with McINTIRE during the
time that he was the Gresham Police Chief and she was a Gresham City Councilwoman,
McINTIRE stated no. McINTIRE acknowledged that GIUSTO was a friend of hers, and that she
worked on his campaign.830 McINTIRE asserted that she is has a very public life, that she has
always been a public safety supporter, but nobody buys me. McINTIRE was concerned that
this allegation may damage her reputation and name and questioned whether it was another
female councilwoman.831 McINTIRE said that rumors had gone around about GIUSTO and her
because they were friends.832 McINTIRE characterized GIUSTO as hes like a mentor and a
dad . . .to me. McINTIRE again expressed her concern about being named in an allegation.
830
Ex A33d, p 5
Ex A33d, p 7
832
Ex A33d, p 8
831

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76. MCSO Tim MOORE

On August 9, 2007, PARSONS and KING interviewed Tim MOORE. After an overview of
MOOREs background, MOORE identified that he had transferred from corrections to the law
enforcement side in January 2006, and that many of the KIM complaints were said to have
occurred prior to that time.833 MOORE stated he did not know KIM. MOORE described the
process for investigating major cases, and commented on the incident involving a male inmate
entering and remaining in a female inmates cell for a period of time.834 When asked about
issues relating to Chaplain STELLE, he stated he had heard rumors and that there had been some
changes in the management of the jail chaplaincy program; that STELLE was working the law
enforcement side.835 MOORE had no first hand knowledge of the allegation that GIUSTO was
contacting a female subordinate or of the JEDDELOH intervention matter. MOORE did not
recall any specific allegation that KIM made that he had knowledge of.836 When asked if there
would be any reason for Commissioner NAITO to request investigators to contact him, MOORE
stated he and NAITO have had a strong relationship; that NAITO knew he would not pull the
wool over her eyes.837
End of conversation
833
Ex A59a, p 6
Ex A59a, p 9
835
Ex A59a, p 11
836
Ex A59a, p 13
837
Ex A59a, p 15
834

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77. Multnomah County Commissioner Lisa NAITO Interview Questions

1. Paugh Complaint: regarding background check of Robert KIM
2. Who is he
3. Title, position
4. Relationship with GIUSTO
5. CORTADA Complaint
6. Who brought his case to you
7. When did they bring it to you
8. What did you do
9. What were the results
10. Have you received any other complaints about GIUSTOs misconduct
11. If so, what, from whom, when
12. Did you personally receive a copy of the anon complaint prior to Robert KIMs letter
which addressed similar allegations, vs. it being sent to the council in general
13. DO YOU HAVE A COPY OF IT
14. In our prior discussion you indicated you referred rumors to County personnel, what
were the rumors
15. When they did come in
16. What was the results
17. You referenced a number of county employees regarding those who may have
information for our investigation
18. Capt Brett Elliott
19. Chief Deputy Tim MOORE
20. Capt Garr NIELSEN (former)
21. Det Jay PENTHENY
22. Deputy Mark HERRON, SIU
23. Kathy WALLIKER
24. Others
25. I understand that you and Sheriff GIUISTO have had a challenging relationship during
the time he has been Sheriff and you have been a councilwoman
26. What difficulties have been noted by the media and others involved in policy making
27. Have there been resolution to them
28. How would others describe your working relationship with GIUSTO
29. Would anyone allege that you would have a personal ax to grind with GIUSTO that
would discount credibility on your part
30. Do you know Jose TORRES
31. Have you had occasion to communicate with him
32. As a councilwoman have you had occasion to met the Tigard business man Robert
KIM
33. In our previous conversation you said that you have gone to bat for GIUSTO on a
number of issues, what were these issues

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78. Multnomah County Commissioner Lisa NAITO Interview Summary

On August 9, 2007, PARSONS and KING interviewed Lisa NAITO at her office for the purpose
of fact finding.
When asked about PAUGH, NAITO stated she may have received a letter from him, as one of
her constituents, and forwarded it to DPSST. When asked about a complaint letter that was
faxed to the Multnomah County Commissioners Office, or to NAITO, she did not specifically
recall this but advised she would ask staff to locate it.838
When asked about a racial harassment complaint at MCSO, NAITO recalled this event and
stated a group of deputy sheriffs within the Union brought the matter to her attention. NAITO
stated she was fairly certain that she brought the matter to the attention of the county attorneys
because she was very concerned about the matter. NAITO recalled that the complaint had been
handled internally and had not been sent to an outside investigator. NAITO stated she has never
met the complainant.839 NAITO did not recall whether she had met with GIUSTO to discuss her
concerns but may have discussed them with Lee GRAHAM.840 When asked if NAITO or her
county counsel directed MCSO to conduct an outside investigation, NAITO did not recall, but
she believed that those issues were under the purview of the sheriffs office.841
When asked if NAITO had heard a rumor about GIUSTO showing up at the jail intoxicated,
NAITO confirmed that she had heard the rumor but not where or from whom she had heard it.
NAITO had also heard a rumor that GIUSTO had said, Were going to Taz someone today
but that it could have been completely unfounded.842
When asked about GIUSTO possibly involved in a sexual harassment incident with a female
subordinate, NAITO stated she had heard the rumor, and that she had forwarded the information
to the county counsel.843 NAITO did not recall receiving anything in writing about this
complaint. When asked if NAITO recalled who had contacted her she stated, I dont want to
answer that, but confirmed that it was a county person.
NAITO stated she did not know complainant Robert KIM and does not believe she has ever met
him.844
When asked about a previous conversation with PARSONS in which she identified a number of
MCSO employees, NAITO stated she was just given those names. . . I havent talked with them
. . .so I dont know directly from them either. The names included Brett ELLIOTT, Tim
MOORE, Gar NIELSEN, Jay PENTHENY, Mark HERRON and Kathy WALLIKER.845
838
Ex A 16e, p 4
Ex A16e, p 7
840
Ex A16e, p 8
841
Ex A16e, p 9
842
Ex A16e, p 10
843
Ex A16e, p 11
844
Ex A16E, p 12
845
Ex A16e, p 13
839

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When asked how she worked with GIUSTO, NAITO stated that they worked together but also
had their differences. NAITO stated that after a number of incidents occurred at MCSO jail, she
asked former Sheriff Noelle to provide her with some insights into the current conditions846,
particularly relating to overtime and finances. NAITO characterized her relationship with
GIUSTO as a positive working relationship. When in doubt, NAITO confers with the county
attorney to see what her appropriate role is, yet understands that each commissioner is
independent and a part of a policy board. NAITO stated she takes her role very seriously and she
will not shy away from issues. NAITO stated that there are times that she has questioned
GIUSTO, but that she has found him to be a team player; she and GIUSTO have agreed more
often than they have disagreed.847 When asked, NAITO stated she does not remember ever
meeting JOSE TORRES.
End of interview.
846
847
Ex A16e, p 14, p 17
Ex A16e, p 20

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79. Chief Garr NIELSEN, Interview Questions

Background
NIELSEN is a former employee of MCSO. NIELSEN was on the law enforcement side of
MCSO until GIUSTO transferred him to the corrections side; a move that was viewed by many
to be a demotion. NIELSEN left MCSO and is now the Chief of Police for Eureka Police
Department, California. NIELSEN has first hand knowledge of some of the KIM allegations.
7. If so, how so
15. Do you have any personal knowledge of the KIM allegation involving a failure to
investigate a racial harassment complaint against a MCSO Lt with outside
investigators.
16. Do you have any personal knowledge of the KIM allegation involving failure to
investigative misconduct against a MCSO sergeant who was involved with another
members wife?
instigation of a complaint against a female sergeant regarding the misuse of time and a
subsequent investigation by a female attorney
18. Do you have any personal knowledge of the KIM allegation involving GIUSTO lying
to investigators, reporters, members of MCSO or the pubic
violating county email policy by sending personal emails to Less Jeddeloh DOSS
20. Do you have any personal knowledge of the KIM allegation involving GIUSTOs
contacts with Margie Goldschmidt while she was still married to Neil
GOLDSCHMIDT
21. Do you have any personal knowledge of the KIM allegation involving GIUSTO failing
to report the child abuse of Neil GOLDSCHMIDT when he became aware of it
engaging in a personal relationship with a Gresham city councilwoman
23. Do you have any personal knowledge of the KIM allegation involving GIUSTO having
improper contact with a MCSO civilian female employee

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engaging in improper conduct with a female volunteer chaplain which affected the
existing male chaplains working environment
25. Do you have any personal knowledge of the KIM allegation of GIUSTO pursuing a
female PPB at a retirement for a male sergeant
26. Do you have any personal knowledge of the KIM allegation of GIUISTO making false
statements to the media about the approval of the CHL to JEDDELOH
27. Do you have any personal knowledge of the KIM allegation that GIUSTO directed his
staff to cover up the application, by either taking the file, or having it altered
28. Do you have any personal knowledge of the KIM allegation that GIUSTO manipulated
or misused the protective order of JEDDELOH, by failing to serve it properly
29. Do you have any personal knowledge of the KIM allegation that GIUSTO engage in a
personal relationship with Lee Jeddeloh DOSS in an effort to conceal his bad act in her
eyes of approving the CHL for Jim JEDDELOH
30. Do you have any personal knowledge of the KIM allegation that GIIUSTO made false
statements to the media about ht nature of his relationship with Lee Jeddeloh DOSS
31. Do you have any personal knowledge of the KIM allegation that GIUISTO used
MCSO equipment to photocopy personal insurance document of Lee Jeddeloh DOSS
or of her children
32. Do you have any personal knowledge of any other misconduct by GIUSTO that has
been alleged by others, or that has been observed by you personally
33. What is/was your relationship with Sean CHRISTIAN
34. Did CHRISTIAN share any information with you about his knowledge of the prior, or
current, letter with allegations against GIUSTO?
35. Is there anything else that we should know or should ask you about this

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80. Chief Garr NIELSEN Interview Summary

On October 4, 2007, PARSONS and KING conducted a telephonic interview with NIELSEN.
After introductions, PARSONS advised that investigators were following up on various
allegations made by KIM. When asked if NIELSEN knew KIM he stated he did not.848
When asked if NIELSEN was employed with MCSO during the JEDDELOH incident, he stated
he was. NIELSEN recalled GIUSTO arranging the intervention and also GIUSTOs efforts to
get MCSO personnel to do a civil standby for Lee (Jeddeloh) DOSS when she was moving
out. NIELSEN stated that he thought GIUSTO was dissuaded from doing that ultimately.849
NIELSEN stated he did not take an active role in the concealed weapons application, that he was
RADERs boss at the time.850 NIELSEN stated we had denied him the concealed weapons
based on those concerns and the sheriff overrode those and . .ordered the permit to be issued.
When asked if NIELSEN knew if anyone talked to GIUSTO about the DV and DUII, or if he
had spoken with GIUSTO, NIELSEN stated he did not believe he had spoken with GIUSTO but
believed that ELLIOTT had spoken to GIUSTO.851
When asked if NIELSEN recalled if GRAHAM was involved, he did not recall. When asked
why he thought GRAHAM had left MCSO, NIELSEN stated that there were a host of reasons
including a vote of no confidence he got from the union and that the sheriff was considering
doing some reorganization at the command staff level which . . .may have included moving him
over to corrections.852
When asked how long NIELSEN had known GIUSTO, he stated since GIUSTO was the Chief of
Gresham Police. NIELSEN provided an overview of his own career path with MCSO.853When
asked if he recalled RADER using the term oreo during a briefing, NIELSEN did recall that
and believed he was RADERs supervisor.854 NIELSEN recalled that RADER was reprimanded
for the comment.
When asked about his knowledge of GIUSTO instigating a complaint against a female
sergeant regarding the misuse of her time, NIELSEN recalled that it was RADER that had filed
the complaint.855 NIELSEN recalled the matter being investigated and also recalled an outside
attorney being hired by the County because OLSEN had made an allegation of harassment
against RADER.856
848
Ex A39c, p 4
Ex A39c, p 5
850
Ex A39c, p 6
851
Ex A39c, p 7
852
Ex A39c p 8
853
Ex A39c, p 9
854
Ex A39c, p 10
855
Ex A39c, p 11
856
Ex A39c, p 12
849

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When asked if he had ever spoken with GIUSTO regarding any knowledge that he may have had
about GOLDSCHMIDTs sex abuse of a girl, NIELSEN stated he had not, and that he had first
learned about it when he read the article in the newspaper.857
When asked if NIELSEN had any knowledge of GIUSTO engaging in improper conduct with a
female volunteer chaplain, NIELSEN stated he knew GIUSTO had a personal relationship with a
female chaplain and there was the impression that she was trying to insert herself officially as a
chaplain within the sheriffs office.858 NIELSEN did not know what impact she may have had
on STELLE. NIELSEN did not know the womans name. NIELSEN stated he thought the
female was on the corrections side and working with inmates.859
When asked what his knowledge was of GIUSTOs relationship with DOSS, NIELSEN stated he
did not think there was any connection between the two of them until the application for the
permit had occurred.860
When asked if NIELSEN knew of an incident in which GIUSTO had contact with a female from
the SIU, NIELSEN stated he did and he confirmed it was McGILL. NIELSEN recalled McGILL
was feeling uncomfortable with GIUSTOs contact with her and another member of the SIU
went to GIUSTO. NIELSEN confirmed that this individual was Sean CHRISTIAN.861 When
asked if he had conversations with GIUSTO or McGILL, NIELSEN did not think that he had.
NIELSEN did state that he spoke with GRAHAM about the matter and about CHRISTIANs
effort to intervene.862
When asked if NIELSEN believed GIUSTO had made statements to the media that were not
truthful or had deliberately misled them in his responses, NIELSEN stated probably.
NIELSEN pointed to the JEDDELOH incident. NIELSEN also stated he was not convinced that
GIUSTO was completely truthful in discussing the GOLDSCHMIDT matter. NIELSEN stated it
just didnt add up that he could be GOLDSCHMIDTs driver and not aware of stuff like that.
NEILSEN stated that he knew enough about the JEDDELOH incident to know that GIUSTO
was not telling the media the whole story. 863 When asked what parts GIUSTO was leaving
out, NIELSEN stated that GIUSTO was trying to utilize personnel from the sheriffs office to
do special favors for [DOSS] and I dont think he ever acknowledged that to the press.864
NIELSEN stated GIUSTOs relationship with DOSS was common knowledge in the office due
to the frequent contacts between GIUSTO and DOSS, and the public appearances DOSS made
with GIUSTO prior to her divorce.865
857
Ex A39c, p 13
Ex A39c, p 13
859
Ex A39c, p 14
860
Ex A39c, p 15
861
Ex A39c, p 16
862
Ex A39c, p 17
863
Ex A39c, p 18
864
Ex A39c, p 19
865
Ex A39, p 20
858

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81. Debby NOAH Interview Questions

1.
2.
3.
4.
5.
6.

7. If so, what
8. If not, why not
things
82. Debby NOAH Interview Summary

On October 4, 2007, PARSONS and KING conducted a telephonic interview with NOAH.
NOAH affirmed that she had been a Gresham city councilwoman from January 1996 to January
2000. When advised that one of the allegations against GIUSTO was that he received special
treatment from a city councilwoman with whom he had a special relationship with, NOAH noted
that there were three women at the time and that she and GIUSTO were not friends outside of
their professional contacts, nor did GIUSTO ask for any special dispensation or courtesies. 866
866
Ex A70c, p 2-3

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83. MCSO Deputy Bobby ODONNELL Interview Questions

Background
ODONNELL is a MCSO Deputy and the subject of one of KIMs allegations. It was
ODONNELLs ex-wife who began to date Deputy RITCHIE.
1. How long have you worked for MCSO
2. What positions have you held
3. In Robert KIMs letter, one of his allegations was that a sergeant was involved with
another officers wife. We have information that indicates that you may have been the
husband of the wife. Is this accurate information
4. We have information that Sgt. Brent RITCHIE may have been the sergeant, is this
accurate information
5. At any time was RITCHIE in a supervisory position over you
6. If so, when
7. Do you believe this created problems in your work environment
8. Do you know if this allegation was investigated
9. If so, what were the results
10. If not, why do you believe that it was not investigated
84. MCSO Deputy Bobby ODONNELL Interview Summary
On August 2, 2007, PARSONS and KING interviewed ODONNELL at his place of
employment for the purpose of fact finding regarding his knowledge of the KIM
allegation.
After a review of his employment background, ODONNELL was asked if he knew Robert
KIM. ODONNELL stated he did not, however he knew his name because of media
coverage.867ODONNELL was asked about the KIM complaint regarding a supervisor
having a relationship with potentially a subordinates wife. ODONNELL identified
Sergeant Brent RITCHIE as the supervisor who had a relationship with his
[ODONNELLs] wife. ODONNELL stated that there was no evidence that RITCHIE
was having an affair with his wife at the time ODONNELL was married to her, and that
his wife and RITCHIE had known each other prior to ODONNELLs marriage to her.868
ODONNELL did stated that RITCHIE had acted as my peer support person for
approximately two years during my divorce. ODONNELL stated he had discussed with
RITCHIE being married and a police officer, as well as how to cope with the strains on a
marriage.869ODONNELL stated RITCHIE began to see his ex-wife after their divorce.
When asked if this created animosity between them, ODONNELL stated, Absolutely on
867
Ex A51a, p 3
Ex A51a, p 4
869
Ex A51a, p 5
868

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my part . . . . affecting my working, yeah. I was emotional at times. I was pissed about
it.870
When asked if this created a hostile work environment, or if ODONNELL had to work
around RITCHIE, ODONNELL stated that they did not work together. r ODONNELL
stated that GRAHAM and NIELSEN were aware of the situation and at one point
ODONNELL became upset with RITCHIE when speaking with a co-worker and told his
co-worker if he ever saw RITCHIE he would kick his ass.871 ODONNELL stated he
took a couple of days off and his ex-wife got a restraining order against him, which was
then dropped. ODONNELL described the situation as a lot of drama and some
colleagues wanted RITCHIE fired, and recalled as the president.872 When asked if
ODONNEL felt the situation had been resolved well by his supervisors, ODONNELL
stated, absolutely,873 and related various methods supervisors used to resolve the matter.
ODONNELL stated now, four years later, he and RITCHIE are very cordial to each
other.874 ODONNELL stated that his ex-wife tried to really jam me up but that
nothing happened.
When asked if ODONNELL knew Robert KIM, he stated he did not and then he
described how he, as a detective, might attempt to identify who might know KIM.875
ODONNELL stated that he had spoken with Sean CHRISTIAN the day prior to
investigators interview about CHRISTIANs involvement in the McGILL/GIUSTO
issue.876 ODONNELL speculated on who may be friends with KIM, but described it as
pure speculation.877 When asked if ODONNELL felt that the matter between he, his exwife and RITCHIE should have been investigated by the sheriffs office, ODONNELL
stated that as he was going through the situation he wanted RITCHIE fired because it
shows absolute lack of integrity. He said RITCHIE used, horrible judgement but that
the sheriffs office ultimately handled it and RITCHIE has apologized a couple of times
about his lack of timing.878 When asked if ODONNELL felt the employer should have
oversight over an employees personal relationships as long as it does not occur on duty,
ODONNELL stated that officers were held to a higher standard and, on or off duty, they
represent the sheriffs office.879 ODONNELL stated he now has an awesome marriage
and his career is good.
870
Ex A51a, p 6
Ex A51a, p 9
872
Ex A51a, p 9
873
Ex A51a, p 10
874
Ex A51a, p 13
875
Ex A51a, p 14
876
Ex A51a, p 15-18
877
Ex A51a, p 18-21
878
Ex A51a, p 22-23
879
Ex A51a, p 24-25
871

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85. MCSO Sergeant Diana OLSEN Interview Questions

Background
September 2004, RADER filed a complaint that Olsen took 10 hours for a 2 hours doctor
appointment. According to HR, OLSEN told them she needed the entire 10-hr day (her normal
shift) because her daughter also had a doctor appointment. OLSEN later asserted that she had
told HR she was physically unable to return to work and that she obtained a doctors slip
excusing her from work for the remaining of the shift. (OLSEN returned to the doctors office
after the IA was started and obtained the doctors slip)
On November 28, 2004 OLSEN wrote a response to IA and assertsed she was being singled
out
The Inspector sustained the violation of improper reporting of sick time and ultimately OLSEN
received a verbal reprimand.
In January 2005, MCSO retained female attorney SAUL to conduct an inquiry to determine if
OLSEN was treated differently based on her gender and economic status. In October 2005, the
investigation ultimately put to rest all issues identified by OLSEN; there was no substantial
evidence in any of the nine areas of OLSENs concern to conclude there were instances or
patterns of discriminatory behavior because she is financially well off.
7. If so, how so
11. Are you aware that Robert KIM wrote a letter to DPSST citing various allegations
against Sheriff GIUSTO
12. In his letter, Robert KIM asserts an allegation that GIUISTO instigated a complaint
against a female law enforcement sergeant for misuse of leave which failed and caused
another investigation of thousands of dollars expense by an outside private female
attorney.
Do you believe Mr. KIM is referring to you?
13. Do you believe that it was GIUSTO that instigated the complaint against you for
misuse of leave?
14. If so, why? If not, who do you believe instigated the complaint?
15. If so, what was the focus of the complaint?
16. If so, what was the outcome of that investigation?
17. Was there more than one investigation regarding misuse of time?

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18. If so, what were the dates of the investigations and the outcomes of the investigations?
19. If any of the investigations were sustained, which ones were sustained?
20. If sustained, did you grieve the out come(s)?
21. If so, what was the result of the grievance?
22. Do you have any outstanding grievances?
23. If so, what is the substance of the grievance(s)
24. If so, where are you in the process of them?
25. Do you know what Mr. KIM is referring to regarding an outside private female
attorney?
26. During his interview, Mr. KIM alleged that you were reprimanded for something that
you did not do. Is this an accurate representation of what occurred.
27. During his interview, Mr. KIM alleged that you were reprimanded because someone
did not like you. Is this an accurate representation of what occurred?
28. During his interview, Mr. KIM alleged that when you filed a grievance with the union
regarding an investigation on your misuse of time, it turned out that it was not your
fault. Is this an accurate representation of the outcome?
29. During his interview, Mr. KIM alleged that you hired a female attorney which cost
thousands of dollars. Did you hire a female attorney?
30. Are you aware that the County hired a female attorney?
31. In your opinion, why did they hire the female attorney to investigate any matter
involving you
32. What was the focus of her investigation?
33. What was the outcome of the investigation?

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86. MCSO Sergeant Diana OLSEN Interview Summary

On September 17, 2007, PARSONS and KING met with OLSEN at her place of employment for
the purpose of fact-finding regarding her knowledge of the KIM allegation.
After a review of her employment background, OLSEN was asked to describe her relationship
with GIUSTO. OLSEN stated that she does not know him on a personal basis. When asked if
OLSEN knew KIM, she stated she did not, nor did she know anyone who knew him.
When asked if the female sergeant in the KIM allegation regarding misuse of leave was she,
OLSEN stated that it was. 880
When asked if OLSEN believed that it was GIUSTO who instigated the complaint against her
for misuse of leave, as KIM alleged, OLSEN stated that GIUSTO did not start the complaint.
OLSEN provided an overview of the issues by stating that the events occurred over a number of
years. OLSEN believed that there was a lieutenant who did not like her and they disagreed on
how to take their vacation time.881 OLSEN identified the lieutenant as Dave RADER and stated
that after their disagreement on time usage, new rules came out and she was told that there would
be a cap put on the amount of time she could accrue. According to OLSEN, the Union became
involved, believing that was contrary to contract.882 According to OLSEN, she was moved from
patrol and placed into a position which required more work and made it more difficult for her to
take time off. When asked if OLSEN believed that this was because of her gender, OLSEN
stated that with RADER she believed it was.883
OLSEN stated that at one point GIUSTO did call her in and told her that if she did not like the
cap on her time, she could self-demote. OLSEN stated she has done everything that has been
assigned to her and she carries way more than most of the guys do, yet she has never
complained to them. OLSEN stated that the employer got wind that she hired an attorney so
they hired an attorney to look into matters.884
OLSEN stated she did not follow through with the lawsuit and the employer backed off.
OLSEN stated that the employers attorney identified eight allegations and that although there
were five allegations that males also suffered, there were three that were unique to her. OLSEN
stated that she and RADER looked at the investigation and her information and the attorney
thought some of the issues were a difference in style between OLSEN and RADER.885 OLSEN
stated that since RADER no longer supervises her she has not had problems.
880
Ex A56c, p 4
Ex A56c, p 5
882
Ex A56c, p 6
883
Ex A56c, p 7
884
Ex A56c, p 8
885
Ex A56c, p 9
881

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When asked what RADERs initial allegation was against her, OLSEN stated that RADER
thought she used too much leave time. OLSEN stated that RADER also filed an internal
investigation against her alleging she misused her sick leave but that allegation was dropped and
she received a verbal reprimand.886
When asked to clarify, OLSEN stated RADER alleged she misused her sick leave because she
had taken the whole day off for a medical appointment. Because she had not notified RADER,
she received a verbal reprimand and she did not grieve the outcome.
OLSEN stated she has no pending grievances against the county. When asked how many people
knew she had hired an attorney, OLSEN stated one or two. OLSEN stated she was passed over
for rank but she did not want it said that she got the rank because she sued so she didnt sue.887
OLSEN stated she did not personally tell anyone in management she had hired an attorney, and
they may have heard about it through gossip.888
When asked if her attorney was male or female, OLSEN stated he was male. When asked if
KIMs allegation that OLSEN had hired a female attorney was incorrect, OLSEN reiterated that
she had hired a male attorney. When asked if KIMs allegation that she was reprimanded for
something that she did not do was an accurate representation, OLSEN asserted it may be correct
because of the long standing practice of reporting sick time. When asked to clarify which
allegation had been sustained against her, based on the records which showed the sustained
allegation dealt with the improper reporting of sick leave for being gone an entire shift for a
doctors appointment, OLSEN stated she did not remember.889
OLSEN affirmed she did not fight the sustained allegation of improper reporting sick leave even
though she believed it was inaccurate. When asked if KIMs allegation that OLSEN was
reprimanded because someone did not like her was accurate, she stated that she believed it was
because RADER did not like her. When asked to clarify that she received a reprimand because
someone did not like her rather than based on her own actions, OLSEN stated yes.890
When asked if KIMs allegation was true, that OLSEN filed a grievance with the Union
regarding the misuse of sick time and the union found that it was not her fault, OLSEN stated she
could not remember whether she had filed a grievance, but did not think she did for the sick
time.891
When asked if OLSEN was aware the County hired a female attorney, she stated she was. When
asked why the County had hired the outside attorney OLSEN stated for the purpose of not being
biased. When asked what the focus of the investigation was, OLSEN stated that it was to
determine if she had a case. OLSEN reiterated the attorneys findings that three of the eight
allegations were unique to her. As clarification, OLSEN was asked if they were unique to her
886
Ex A56c, p 11
Ex A56c, p 13
888
Ex A56c, p 14
889
Ex A56c, p 17-19
890
Ex A56c, p 20
891
Ex A56c, p 21
887

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because she was the only female sergeant with the agency. OLSEN stated the attorney didnt
comment on that, but that the attorneys investigation was slanted because they had a prior
female sergeant, five to six years earlier. OLSEN asserted that female sergeant had gone off on
disability due to a work-related nervous breakdown.
When asked about the countys findings which included, ultimately the investigation puts to rest
all issued identified by Olsen. There was no substantial evidence in any of the nine areas of
Olsens concern to conclude that there were instances or patterns of discriminatory behavior
because she is financially well off or gender, Olsen offered that she thought there were eight
issues.892 She also said the attorney told her there was a difference with these issues.
When asked if OLSEN felt GIUSTO adequately addressed her concerns through an internal
investigation as well as through the outside attorneys investigation, OLSEN stated she did not
and that she felt GIUSTO was trying to cover his own ass. When asked to clarify that,
OLSENs perspective was that GIUSTO did not adequately handle the investigation when asked
what GIUSTO should have done, OLSEN stated it was handled poorly and that it was not
necessary to hire that attorney. OLSEN felt that the investigation was not to take care of her
issues but to protect their issues.893
For clarification, OLSEN was asked to confirm that she had an issue with vacation time in 2003,
and an issue with misuse of sick leave in 2004, with the independent attorney coming in 2005 for
the purposes of covering nine areas of OLSENs concerns. OLSEN confirmed this timeline was
accurate.894
892
Ex A56c, p 24
Ex A56c, p 26-27
894
Ex A56c, p 30
893

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87. MCSO HR Director Jennifer OTT Interview Questions

Background
OTT serves as the MCSO Human Resource Director. OTT was incorrectly named by
complainant KIM as the victim of GIUSTOs attentions and subsequent threats. OTT can
provide information on the McGILL issue.
1.
2.
3.
4.
5.
6.
7.
8.

If so, how so
Do you recall a time that you became aware of communications between GIUSTO and
McGILL that was other than work related
10. If so, how did you become aware of this
11. Have you ever seen the communications or a copy of the communications
12. If so, what do you recall the communications contained
13. What did you do with the information you had
14. Did you discuss this information with Chief Deputy GRAHAM
15. If so, what did you discuss with him
16. Did you and he decide how to handle this matter
17. If so, how did you decide to handle it
18. At some point did you contact McGILL about this situation
19. If so, when and what was discussed
20. At any point did you communicate with McGILL that if she divulged GIUSTOs
communication with her, her job would somehow be in jeopardy?
22. If not, do you have any idea how this assertion could have been interpreted as such
23. Do you believe that this matter has been resolved?
25. What would you have liked to have been handled differently
34. Do you know anyone who knows Robert KIM.

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88. MCSO HR Director Jennifer OTT Interview Summary

On August 9, 2007, PARSONS and KING interviewed OTT over the telephone for the purpose
of fact finding regarding what knowledge she had about KIMs allegation of inappropriate
contact by GIUSTO. When asked if she had occasion to contact Deirdre McGILL regarding
MCGILLs concerns about contact between GIUSTO and her, OTT stated that approximately
three years ago, Lee GRAHAM contacted her about concerns brought forth by members of the
law enforcement division.895
As the Human Resources Director for MCSO, OTT had the responsibility to meet with McGILL
and determine if there was an informal or formal complaint of harassment and determine whether
an investigation should occur. She met with McGILL and shared the concerns with her.
McGILL told OTT that she thought she had taken care of it. McGILL never referred to her
contact with GIUSTO as harassment, sexual or otherwise. McGILL did state to OTT that
GIUSTO would stop by and speak with her.896 On one occasion they discussed McGILL going
to the beach with her dog, but nothing happened from that. McGILL did tell OTT that she and
GIUSTO had discussed traveling and wines and because GIUSTO is Italian, he had an interest in
wines. OTT stated that McGILL was upset that people were still talking about GIUSTO and her,
although it appeared that McGILL was the one actually stirring the pot because although
McGILL did not find GIUSTOs subsequent interactions uncomfortable, she was still talking
about these interactions with the detectives.897
OTT stated that at one point McGILL related a strange page that she received so she asked
GIUSTO if he had called her and he told her no. When asked by OTT if she was still getting
unwanted attention, McGILL had told her she was not, and that she did not feel that the contacts
rose to the level of filing a complaint.898 OTT notified McGILL that the sheriff had been
spoken to about this . . .and its been handled. When OTT asked McGILL if she felt any
further action needed to occur, McGILL told her no.
When asked if OTT communicated with McGILL in any way that if McGILL divulged
GIUSTOs communications her job would be in jeopardy, OTT affirmed that her discussion with
McGILL was not retaliatory in any way. OTT stated that at the point she talked to McGILL, she
had not even talked to GIUSTO yet; OTT believed that GRAHAM spoke with GIUSTO.899 OTT
stated she made it clear to McGILL that if she had any additional interaction with GIUSTO she
needed to come to OTT directly.900
When asked if OTT knew Robert KIM, she stated she did not.
895
Ex A25b, p 2
Ex A25b, p 3
897
Ex A25b, p 4
898
Ex A25b, p 5
899
Ex A25b, p 6
900
Ex A25b, p 7
896

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89. MCSO Detective Jay PENTHENY Interview Questions

Background
NAITO named PENTHENY as an individual who may have information regarding this
investigation. NAITO provided no additional insights regarding the area of interest.
3. The reason that we have asked to speak with you is Commission NAITO gave DPSST
a number of names of MCSO employees to speak with in the belief you may have
information in the fact finding investigation that we are conducting.
5. Do you know anyone who knows Robert KIM.

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90. MCSO Detective Jay PENTHENY Interview Summary

On August 13, 2007, PARSONS and KING interviewed PENTHENY at his place of
employment. The purpose of the interview was a fact finding regarding his personal knowledge
of any allegations against GIUSTO.
After a review of his employment history, PENTHENY was advised that his name had been
given to investigators by Commissioner NAITO who indicated he may have first-hand
information about some of the allegations against GIUSTO.
PENTHENY stated he has never seen the letter, but has seen the newspaper regarding the
allegations. When asked if PENTHENY had first-hand knowledge of any of the allegations,
PENTHENY stated he had no direct knowledge, beyond that of a Union representative.
In response to inquiry PENTHENY stated that the allegation of a sergeant dating the wife of a
deputy did not occur. PENTHENY stated that the relationship began after the separation or the
divorce was pending.901
PENTHENY affirmed that he was involved as a Union representative with some of the instances
KIM referred to. When asked about KIMs allegations that these instances were not investigated
or handled properly, PENTHENY affirmed they were investigated and there was nothing that he
could recall that was just pushed under the carpet, not dealt with. PENTHENY stated that
there may be instances in which the Union and management disagree on punishment or
decisions.902
When asked if he knew KIM, PENTHENY stated he did not, nor did he know anyone who knew
KIM. PENTHENY stated the allegations make the deputies look bad and he would like to see
people come forward and deal with [the issues]. PENTHENY stated this was causing turmoil in
the [agency].903
When PENTHENY was asked, as a Union representative, if it was the business of the sheriffs
office to look at the personal lives of employees and who they were dating, PENTHENY stated
he did not believe so.
901
Ex A58a, p 5
Ex A58a, p 6
903
Ex A58a, p 8
902

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91. MCSO Lt. Dave RADER Interview Questions

Background
RADER is a Lieutenant with MCSO. RADER was named by CORTADA as the individual who
used the word oreo to describe a mentally ill individual being restrained by sandwiching him
between two boards. RADER was named by OLSEN as the individual who complained about
her use of time and her use of sick leave.
1. How long have you served with MCSO
5. When is the first time you met Rafael CORTADA
8. If so, how so
9. Do you recall a time that he was present when you were talking and you used the term
oreo?
10. If so, describe the circumstances and content of the discussion
11. Who else was present
12. At the time of the discussion, were you aware that anyone present was offended
13. If so, whom and how did you become aware of this
14. If not, were you made aware that someone was offended
15. If so, who made you aware
16. If so, what was your response
17. At some point did you have a discussion with Chief Deputy Lee GRAHAM about this
matter
18. If so, what was the content of the discussion and when did it occur
19. At any point you tell GRAHAM that you were remorseful and wanted to apologize to
Cortada
20. If so, what was GRAHAMs reaction
21. Did this apology take place
22. If not, why not
23. Did you receive any discipline or sanctions as a result of this event
24. If so, what were they
25. Do you feel that this matter has been resolved to your satisfaction
Robert KIMs sources might be, If so, who have you heard they are

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92. MCSO Lt. Dave RADER Interview Summary

On July 26, 2007, PARSONS and KING met with RADER at the MCSO office. The purpose of
the interview was fact- finding regarding his first hand knowledge of any of KIMs allegations.
After providing his employment background, when asked when he first met GIUSTO, RADER
stated it was when GIUSTO was a candidate for Sheriff.904 RADER characterized his
relationship with GIUSTO as strictly business. When asked the first time RADER had met
CORTADA, RADER stated it was shortly after CORTADA was hired and that he has known
him for six or seven years.905 When asked if he recalled a time and the circumstance in which
RADER used the term oreo, RADER stated he was the operations lieutenant and he attended
roll calls. At one such roll call there was a discussion about Caliber Press and their training
seminars. RADER related an incident that had occurred while he was a probationary deputy in
which he responded to a disturbance.906 After hearing screaming and yelling, and water coming
from an apartment unit, he observed a tall African-American male standing at the doorway
with his fists clenched. The individual was non-compliant and non-responsive. Back up units
arrived and after a period of time all took control of the individual by restraining him and
strapped him to two backboards, like an oreo cookie. RADER asserted that prior to that roll
call he had never heard the term oreo used or identified as an inappropriate or discriminating
comment. RADER stated that shortly thereafter he was called in by GRAHAM who asked him
about the oreo comment. Once RADER found that CORTADA had taken offense to his
comment, RADER wanted to apologize, and asserted that in the fourteen or fifteen years of his
employment at MCSO, he had never been accused of being a racist and he believed the comment
was taken out of context and out of proportion.907 RADER stated that GRAHAM and the Union
were at battle and he got caught up in the fray.908
RADER stated that later he was contacted by either GRAHAM or MOYER and told that
GIUSTO wanted the matter resolved and that he was to meet with GIUSTO and CORTADA.
RADER recalled that they all met, he and CORTADA shook hands and he does not believe there
is animosity between the two of them today. RADER stated that CORTADA related that there
was something in his past that caused the term oreo cookie to be offensive for him as an
individual so RADER apologized to him.909
RADER stated that when GRAHAM initially contacted him he had told GRAHAM that he
wanted to apologize to CORTADA but GRAHAM told him to stay out of it.910 RADER stated
as a result of the incident he received verbal counseling and the matter has not been raised again
until now.911
904
Ex A 40a, p 3
Ex A40a, p 5
906
Ex A40a, p 6
907
Ex A40a, p 6-11
908
Ex A40a, p 12
909
Ex A40a, p 13
910
Ex A40a, p 14
911
ExA40a, p 15-16
905

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When asked if RADER knew Robert KIM, he stated no.912 RADER stated he knew of no one in
the agency that knew KIM. In response to KIMs allegations RADER stated that at that time
there was discord in the agency and that the Union had an agenda, GRAHAM had an agenda and
a couple of people had private agendas. When asked who, RADER identified Diana OLSEN.
RADER explained that OLSEN had been taking an inordinate amount of leave time to the
point that she was gone more than she was at work.913 RADER said that there were meetings to
determine how to manage the time and OLSEN was not happy about it and threatened a
lawsuit.914
RADER also explained that there were a couple of anonymous letters sent alleging inappropriate
conduct or activities. RADER described one such allegation against him which was proven
false.915
RADER commented that he thought the investigators were there to talk to him about GIUSTOs
issuance of the CHL because he was the issuing authority for the sheriff at the time and he was
unaware that KIM had included his incident with CORTADA in his allegations.916
912
Ex A40a, p 17
Ex A40a, p 18
914
Ex A40a, p 19
915
Ex A40a, p 20-21
916
Ex A40a, p 23
913

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93. Jim REDDEN Portland Tribune

(Ex A12.97) I dont even know the guy . . .
(Ex A12.97) Giusto says he cannot recall hearing any rumors about Goldschmidt and an
underage girl . . .
1.
2.
3.
4.
5.
6.
7.
8.

Confirm the author
and if retained
9.

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94. MCSO Sgt. Brent RITCHIE Interview Questions

Background
RITCHIE is the subject of one of KIMs allegations; he is the individual who provided peer
support to ODONNELL and then dated ODONNELLs wife after they divorced.
1. How long have you worked for MCSO
2. What positions have you held
3. Have you ever been involved in peer support while working with MCSO
4. If so, what training have you received in peer support
5. Describe what peer support involves
6. Have you ever had occasion to work with Bobby ODONNELL
8. Were you in a supervisory position over ODONNELL
9. After serving as a peer support for ODONNELL while he was going through marital
problems, did you subsequently begin a relationship with ODONNELLs wife
10. Do you believe this created problems or conflicts in your work environment
11. Were you ever transferred as a result of your relationship with ODONNELLs wife
12. If so, describe
13. Do you know if this allegation was investigated
14. If so, what were the results
15. If not, why do you believe that it was not investigated
16. Do you feel that there was an ethical dilemma in developing a relationship with a
subordinates wife/counselees wife
17. Were you ever counseled regarding unethical conduct or the appearance of unethical
conduct that resulted from your choice to date Mrs. ODONNELL

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95. MCSO Sgt. Brent RITCHIE Interview Summary

On August 13, 2007, PARSONS and KING interviewed RITCHIE at his place of employment.
After a review of his employment history, RITCHIE was asked if he was involved in the peer
support program. RITCHIE stated he was and when asked to describe the type of training he
received, he described training in stress and traumatic incidents. When asked if he had occasion
to be peer support to Bobby ODONNELL, RITCHIE stated he had.917 When asked under what
circumstances RITCHIE provided peer support, he stated it was confidential. When advised that
it was the investigators understanding that he provided peer support to ODONNELL for marital
problems and that at some point he began a relationship with ODONNELLs wife, RITCHIE
stated that was not correct. RITCHIE refused to comment on what he was a peer support for
ODONNELL for, he stated he did not know if ODONNELL was having marital problems.
RITCHIE asserted he did not start dating ODONNELLs wife until she was his ex-wife.918
When asked if seeing ODONNELLs ex-wife created problems for RITCHIE and him at work,
and because he was a supervisor and ODONNELL was a subordinate, RITCHIE stated that
there were not incredible difficulties because GRAHAM had ordered him not to see
ODONNELL, talk to him or go anywhere near him.919 RITCHIE felt that GRAHAM was
collecting a file on him for discipline for seeing ODONNELLs ex-wife. RITCHIE stated there
was never an investigation on the matter.
When asked if his seeing ODONNELLs ex-wife created problem at work because he was a
supervisor, RITCHIE stated he was never ODONNELLs supervisor.920 When asked if his
relationship caused friction among other officers RITCHIE affirmed it had. When asked if there
were consequences as a result of his relationship, RITCHIE stated there were indirect
consequences, such as another officer witnessing ODONNELL in front of their place of
employment with a gun and threatening to kill RITCHIE.921 RITCHIE stated that Laura,
ODONNELLs ex-wife, filed for a restraining order which was subsequently entered as a civil
agreement.
When asked if RITCHIE thought there may have been an appearance of engaging in unethical
conduct by dating the ex-wife of someone he was counseling, RITCHIE stated that he only
talked to ODONNELL twice and that it was prior to the divorce. RITCHIE stated he had known
ODONNELLs ex-wife prior to when they were married. 922 When asked if RITCHIE was
counseled by a superior about what appeared to be unethical conduct, RITCHIE stated there
were several meetings and it was a big topic for discussion.
917
Ex A60a, p 3
Ex A60a, p 4
919
Ex A60a, p 4
920
Ex A60a, p 5
921
Ex A60a, p 6
922
Ex A60a, p 8
918

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When asked if RITCHIE was the Union president at one time, he affirmed he was. When asked
about KIMs allegation that this matter should have been investigated and that his agency should
have the latitude to investigate something that occurred in personal lives, RITCHIE stated that
was not appropriate.923 When asked if there were a point in which the agency should step in and
investigate the consequences that may occur on duty, RITCHIE agreed that if it got to that point,
it may be appropriate.924
RITCHIE asserted that at one point he did ask for the matter to be investigated because he was
accused of things that he did not do. RITCHIE stated that a couple weeks after ODONNELLs
and Lauras divorce he and Laura talked about telling ODONNELL about their relationship and
it was finally decided that Laura should tell him.925 When asked if KIMs allegation was
legitimate, that GIUSTO should have investigated the matter and did not, RITCHIE stated he
would not fault GIUSTO for not investigating it, but would fault him for not taking more of a
leadership role in stopping the rumor mill.926
When asked if RITCHIE knew KIM, he stated he did not and does not know anyone who knows
KIM.
923
Ex A60a, p 9 - 11
Ex A60a, p 12
925
Ex A60a, p 14
926
Ex A60a, p 15
924

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96. MCSO Deputy Marshall ROSS Interview Questions

Background:
ROSS was identified as having an involvement in the intervention.
1.
2.
3.
4.
5.
6.
7.
8.

If so, how so
I understand you were involved in the intervention matter concerning GIUSTO and
JEDDELOH
command staff

Investigation #2
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97. MCSO Deputy Marshall ROSS Interview Summary

On July 26, 2007, PARSONS and KING interviewed ROSS at his place of employment. The
purpose of the interview was to determine his involvement in the intervention of JEDDELOH.
After providing his employment background, ROSS was asked what his relationship with
GIUSTO was. ROSS characterized it as a working relationship. 927 ROSS was asked if during
the intervention he was following the directions of either his commanding officer or GIUSTO
and ROSS stated he was. ROSS stated his role was that of a civil deputy and GRAHAM
directed him to be present with a family abuse prevention act restraining order and domestic
relations dissolution of marriage lawsuit.928 ROSS was asked if he had any concerns about the
manner in which the incident unfolded and he stated, no.
ROSS was asked if he knew Robert KIM and he stated he did not, nor did he know any others
who knew KIM.
927
928
Ex A41a, p 3
Ex A41a, p 4

Investigation #2
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98. Jacob SANDERS, Portland Tribune
contact us.

Investigation #2
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1/16/2008
99. Senate Rules Testimony

See Exhibit A75b

Investigation #2
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100.
MCSO Deputy Todd SHANKS, Interview Questions
Background:
SHANKS is the MCSO Union President for the law enforcement side. SHANKS was contacted
by investigators regarding limited confidentiality of the KIM sources.
1. Can you assist in identifying the KIM sources?
2. MCSO MCCAIN/GIUSTO agree not to seek identity of sources unless contested case
hearing
3. If sources do not come forward, investigators may need to seek to identify them

Investigation #2
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101.
MCSO Deputy Todd SHANKS, Interview Summary
On July 16, 2007, KING made telephone contact with SHANKS for the purpose of determining
if the Union could or would provide assistance with identifying KIMs sources.
KING identified a number of allegations that KIM had made against GIUSTO, and that his
information was not first-hand but that KIM was asserting his three MCSO sources did have
first-hand information. KING related to SHANKS that, according to KIM, the MCSO sources
were fearful of retaliation, therefore did not want to be identified.929
KING advised SHANKS that investigators had contacted GIUSTOs office and MCCAIN had
assured KING that they [GIUSTO] would not ask for the identities of the deputies or personnel
up until and unless the case went to a contested case hearing.930
KING advised SHANKS that KIM had provided certain identifiers that may lead to the sources
discovery, in lieu of them coming forward. When provided with the two options of determining
who KIMs sources were, KING asked if SHANKS could or would assist in the process.
SHANKS first asked whether it had been determined if the sources were from the law
enforcement side or the corrections side; there were two different unions representing them.931
KING expressed that it appeared the sources were from the law enforcement side.
KING advised that she wanted to return to KIM and provide him the opportunity to contact his
friends and advise them of the partial confidentiality agreement, but was checking with
SHANKS, for his thoughts. SHANKS indicated that he was not interested in entertaining the
notion of either assisting in the investigation or identifying his members. When KING explained
the concern to protect an individual concerned about retaliation, SHANKS stated if the sources
were worried about retaliation they could obtain an attorney.
End of conversation
929
Ex A 36a, p32
Ex A36a, p 3-4
931
Ex A36a, p 7-9
930

Investigation #2
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102.
Phil STANFORD, Portland Tribune
contact us.
103.
(Ex A12.98) Giusto didnt know about the substance of the story until he read about it in the
papers . . . he cant remember when, or even if, he had hard [the rumor] . . .
1. Identify the newspaper article by date and title
2. Confirm the author
3. Determine if there was more than one author
4. Determine if the author is the individual who interviewed Giusto, if not who was
5. Determine if the interview was conducted via phone or in person
6. Determine if there were any other individuals present during the interview
7. Determine if the interview was recorded; and if so, if the recording has been retained
8. Determine if there were notes of the conversation taken and if so, who took the notes,
and if retained
9.

Investigation #2
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104.
Chaplain Ed STELLE Interview Questions
Background:
STELLE has been a chaplain for MCSO since 1983. Prior to that he spent approximately 30
years with PPB as a chaplain.
1.
2.
3.
4.
Are you currently working for Sheriff GIUSTO or MCSO?

What is your position with MCSO
Have you ever been a full time employee
Do you recall a female volunteer chaplain that GIUSTO invited to also work at MCSO
as a volunteer
5. If so, what was her name
6. If so, what date did she come into the program
7. Describe your interaction with the female chaplain volunteer
8. After the female chaplain volunteer came onto the scene, did your role, your hours or
your salary change
9. If so, how
10. Did you have any discussions with GIUSTO about the changes
11. How did you feel about the changes
12. Do you have any concerns with how this matter was handled?
15. Is there anything else we should know

Investigation #2
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105.
Chaplain Ed STELLE Interview Summary
On July 16, 2007, PARSONS conducted a telephonic interview with STELLE. The purpose of
the interview was fact-finding regarding an allegation that STELLE, his employment, or his
position had suffered as a result of GIUSTO bringing in a female chaplain with whom he had a
personal relationship.
When advised that there had been a complaint that when STELLE was working full time as a
chaplain a female friend of GIUSTO, a volunteer chaplain, was then brought in, causing
STELLEs employment to be cut to half time, STELLE commented that the complaint was only
partially true.932
STELLE said he had been with MCSO since 1983 and that he was not working for the money,
but for his ministry; he has never been a full-time employee.933 STELLE said that he had
developed the jail program into a large program. STELLE said GIUSTO did have a female
friend who was a chaplain and asked STELLE to interview her, which he did.934 The female
chaplain went through training. At some point GIUSTO told STELLE that he wanted him to
focus full-time on the law enforcement side, to which STELLE agreed. STELLE stated that
MCSO is currently paying him half time but reiterated that he is not there for the money.
STELLE said that GIUSTO encouraged him not to leave the program, but to cut back, and
GIUSTO was having a staff person become the organizer of the program. STELLE said that
although he did leave the jail side, GIUSTO never changed anything with him regarding his
vehicle, or the amount of money he was being paid.935 STELLE stated he has never received
benefits such as a health plan or pension, so they were not an issue.
STELLE stated that in July [2006] GRAHAM told him that there was no more money and
STELLE told GRAHAM that was fine, that he was ready to go.936 Later, GIUSTO contacted
STELLE and told him that [MCSO] really did not want him to leave, because there was so much
going on. GIUSTO told STELLE that because of budget issues, they were making cuts.
STELLE stated that GIUSTO told him that because his deputies relied upon him, GIUSTO did
not want STELLE to leave. STELLE characterized GIUSTO as being decent toward him.937
When asked who the female chaplain was, STELLE could not recall her name, and stated she
was no longer around. STELLE believed that Catherine MOYER ran the corrections chaplain
program.938 STELLE reiterated that the female chaplain, who had been on the corrections side,
probably three years ago, was probably not there anymore.939 When asked how long after the
female volunteer came along STELLE was transferred from [corrections] to [law enforcement]
he estimated it was nine months to a year. STELLE then stated it was a relief for him because he
932
Ex A34a, p 3
Ex A34a, p4
934
Ex A 34a, p5
935
Ex A34a, p 6
936
Ex A34a, p 7
937
Ex A34a, p 9
938
Ex A34a, p 10
939
Ex A34a, p 11
933

Investigation #2
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was putting in 60-70 hours a week and also, his heart was really with the cops and their
families940
When asked whether there was ever a rumor that GIUSTO was romantically involved with the
female chaplain, STELLE stated that he did not know.941
End of conversation
940
941
Ex A34a, p 13
Ex A34a, p 14

Investigation #2
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106.
Arthur SULZBERER, Oregonian
contact us.
(Ex A12.6) It was all very vague some gal, some time, some place, he told The Oregonian
in 2004, describing one conversation with Leonhardt.
(Ex A12.32) Giusto said Thursday that he had been unaware of allegations of domestic violence
when he signed the license.
(ExA12.116) In February 2005, Giusto approved Jeddelohs application for the concealed
handgun permit. He later said he had done so before learning Jeddeloh had a drunken driving
conviction. . . In a July 23, 2005, interview with The Oregonian, Giusto was asked about
traveling to Seattle with Doss in May 2005. I didnt take a trip to Seattle, he said.
Confirm the author
and if retained
9. Determine the timeframe from when the interview was conducted until the article was
1.
2.
3.
4.
5.
6.
7.
8.

Investigation #2
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107.
Victoria TAFT, News Talk 860 Summary
Background
During June 2004, GIUSTO was interviewed by TAFT, News Talk 860. During her interview,
TAFT referred to news article which reported LEONHARDTs assertions relating to the
GOLDSCHMIDT crime.942
When asked if GIUSTO knew LEONHARDT, he stated he does, but has not seen him in
probably ten years.943 GIUSTO recalled that LEONHARDT stated that he [LEONHARDT]
heard it first at the Dakota Caf. GIUSTO clarifies, that would indicate that he
[LEONHARDT] got the information that he claims he got from he before he got it from
me.944
When asked if GIUSTO talked with LEONHARDT about the girl regarding any aspects of the
situation, general or specific, GIUSTO stated, I may have . . .I have no independent
recollections of any conversations with him. GIUSTO then stated, . . .he had the information
before I did, and I believe that if anybody initiated it, he probably did. . . I have no independent
recollection of the conversation.945 When asked if GIUSTO was saying that he heard from
LEONHARDT about the girl GIUSTO replied, No. . . I do not have any independent
recollection of a conversation that had any merit or any substance with Fred Leonhardt.946
When TAFT asked GIUSTO, Whered you first hear about it? GIUSTO replied, When you
heard about it in the Oregonian. When asked if GIUSTO was going on record as saying he had
never heard this story, GIUSTO replied, No . . .I said I didnt hear the detail . . .I heard lots of
rumors about different things while I was in the governors office.947 When TAFT asked
GIUSTO if he had heard the rumor about the girl, GIUSTO replied, I heard - - I couldve heard
a number of rumors. When asked if GIUSTO heard the specific rumor, GIUSTO stated he had
heard tons of rumors in the governors office. 948 When TAFT stated, This is a pretty big one
. . . it seems to me that you might have remembered this one GIUSTO replied, If I heard the
rumors - - all the details, you bet Id remember.949
When asked if GIUSTO recalled offering LEONHARDT a ride and stopping for breakfast, and
asked, Did this happen? GIUSTO replied, could have. When asked if GIUSTO discussed
with LEONHARDT that GOLDSCHMIDT had sex with an underage girl, GIUSTO replied, I
have no independent recollection of any conversation like that with Fred Leonhardt.950
942
Ex A74a, p 2
Ex A74a, p 4
944
Ex A74a, p 5
945
Ex A74a, p 6
946
Ex A74a, p 9
947
Ex A74a, p 10
948
Ex A74a, p 11
949
Ex A74a, p 12
950
Ex A74a, p 13
943

Investigation #2
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When asked what GIUSTO meant by independent recollection GIUSTO replied, . . .

meaning without anybody saying that I had it or prompting me . . .
When asked if GIUSTO told the Oregonian he did not recall the breakfast, but acknowledged
that it was possible that the two drove together to Salem and discussed rumors about
GOLDSCHMIDT, GIUSTO said he did. When TAFT stated that GIUSTO was quoted as
saying, some gal, some time, some place . . and that.he denied telling LEONHARDT any
specific details about the girl, GIUSTO stated . . .because I didnt have them.951
When asked if he and Margie GOLDSCHMIDT were lovers, and if Margie GOLDSCHMIDT
would have known about the rumors, GIUSTO stated that they dated. When GIUSTO asked
why this was a part of the story, TAFT asked if Margie GOLDSCHMIDT ever told GIUSTO,
and he stated no.952 GIUSTO asserted that he had told the Oregonian the first time I heard
about it was when I knew she had to reopen the divorce for some kind of civil settlement . . .
When TAFT asked GIUSTO if he would have us believe you never discussed him [Neil
GOLDSCHMIDT] and this allegation [with Margie GOLDSCHMIDT] GIUSTO stated that he
knew when Margie had to reopen this thing.953
TAFT pointed to LEONHARDTs assertion that a pivotal moment occurred at a holiday party
at Margie GOLDSCHMIDTs, who was then divorced and romantically involved with
GIUSTO. TAFT asked GIUSTO if he remembered that party. GIUSTO stated, no, I dont
remember the party . . . I couldve have been there . . . Yes, I was at a party where Fred was at a
party.954
GIUSTO stated LEONHARDT had never closed the loop and that he never told me that he
was quizzing me for the governor. When TAFT asked how GIUSTO could recall this portion
of the conversation, or lack of conversation, if he could not recall being at the party, GIUSTO
stated, If he had told me he was quizzing me to get information for Ted Kulongoski because of
this situation, I dont remember that. Thats why I dont remember the conversation.955
TAFT pointed to LEONHARDTs assertion that he told KULONGOSKI beforehand that he was
going to quiz GIUSTO about the abuse allegations at the party. TAFT commented that
GIUSTO indicated to LEONHARDT, it was going to hit the fan and GIUSTO stated, Thats
wrong. When TAFT asked if GIUSTO knew if the victim was asking for money, GIUSTO
stated, I did not know that she was asking - - I didnt - - I didnt - - there was going to be a
settlement, there was ever a settlement, I had no information about that at all. None. 956
TAFT asked GIUSTO if it was true that GIUSTO had told LEONARDT the names of some of
the lawyers involved GIUSTO stated, no and asked why LEONHARDT didnt jump into the
951
Ex A74a, p 14
Ex A74a, p 15
953
Ex A74a, p 16
954
Ex A74a, p 17
955
Ex A74a, p 19
956
Ex A74a, p 20
952

Investigation #2
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fray earlier since he also knew of the information. TAFT stated she thought that was a
legitimate question.957
GIUSTO stated to TAFT that I had no detail that was meaningful enough for him
[LEONHARDT] to make these kind of claims. I never had that kind of detail . . .958
GIUSTO stated that he has never communicated with the victim or her family. GIUSTO stated
that this happened in the 70s and he started with the State Police in 74. GIUSTO stated the
word investigation implies that there is some kind of a crime. Did I have a legal responsibility
to do that [report it] No, I did not. Did I have an ethical responsibility? Thats an individual
question for me. The answer is yes, I - - I wouldve - - at least asked questions to be sure there
were no other victims.959
When GIUSTO asserted that he did not have a basis for investigating this rumor, TAFT stated,
. . . seldom does a case appear on your desk thats fully done before an investigation has been
done and asked GIUSTO if someone would have to start asking questions, [about the rumor].
GIUSTO replied that we dont investigate rumors because well ruin everybodys life based on
rumors. GIUSTO explained that the rumors would have to have substance that could be
verified, to which TAFT asked GIUSTO how they could be verified without investigating them.
GIUSTO responded that there was a difference between a full fledged investigation as opposed
to would I make inquiry about it relative to an ethical responsibility because the crime was no
longer involved.960
When TAFT commented that two other people, John BRANDT and Ginny BURDICK, said that
LEONHARDT told them of the details of the GOLDSCHMIDT allegation before the story
broke, and asked GIUSTO if he didnt tell LEONHARDT, GIUSTO stated, I didnt tell him the
kind of facts hes alleging.961 When TAFT asked GIUSTO if he thought LEONHARDT was
making everything up, GIUSTO stated, . . .he also said that he saw the girl in the Dakota before
he knew me. When asked why LEONHARDT would pick GUISTO out of everyone to pin
this on and asked what LEONHARDT had against GIUSTO, GIUSTO stated I dont think he
has anything against me.962 GIUSTO asserted that LEONHARDT was hurt by the prior
administration and really wasnt fond of the other administration..
When TAFT asked should there be evidence that GIUSTO knew, and he was shown to be
covering up for this guy after raping a kid, what are you prepared to do to the voters of
Multnomah County, would you resign? GIUSTO replied, . . .Let me go back and say that
there was no crime . . . .the crime was long past when I even came to the Goldschmidt
administration. So there was no crime to cover up. . . .the statute of limitations had run. .. .there
was no crime to cover up.963 When TAFT asserted there had been a crime, GIUSTO replied,
957
Ex A74a, p 21
Ex A74a, p 21
959
Ex A74a, p 23
960
Ex A74a, p 24
961
Ex A74a, p 24
962
Ex A74a, p 25
963
Ex A74a, p 27
958

Investigation #2
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there was a crime . . .the crime ended in 81 because thats the date that the statute runs.964
GIUSTO asserted that Oregon had changed the victimization statutes, but [the victim] was
way past that even.
When TAFT commented on GIUSTOs relationship with the governors wife and questioned
whether there was intimate talk between the two of them, GIUSTO stated, Well, thats
presuming that you think that the person youre talking about knew everything that there was to
know. TAFT replied that she [Margie GOLDSCHMIDT] had to know and the court papers said
that she did know. GIUSTO stated No. When asked if Margie GOLDSCHMIDT was a part
of the confidentiality agreement, GIUSTO stated he did not know.965
TAFT asked GIUSTO if he wanted to stay and take a couple of telephone calls; he stated he
could. As TAFT provided a recap of the Oregonian article, GIUSTO clarified, Im not claiming
that Mr. Leonhardt got all the details. That Mr. Leonhardt whatever details he got with any
substance didnt come from me.966
Caller Chance asserted that GIUSTO early on in the interview GIUSTO had stated, I dont
specifically recall that happening, but it could have, however later in the interview, GIUSTO
became very adamant that those didnt happen. Caller Chance stated he was curious when
GIUSTO didnt remember either, how he could be sure one did not [happen] but one
[conversation]could have.967 GIUSTO responded, . . . .When I use absolutes as in I absolutely
never talked about anything relative to this subject with anybody 15 years ago - - thats a bad
position for me to be in. When I can absolutely tell you that I didnt have any details to talk
about. That I know independent of myself . . .968
TAFT asked if GIUSTO had heard KULONGOSKIs reply to LEONHARDTs assertions and
GIUSTO stated he had not. When TAFT quoted LEONHARDTs reponse to KULONGOSKIs
reply, I deeply regret the governors memory lapse, I unfortunately found the story hard to
forget GIUSTO stated, If he was so bothered about it, he shouldve have (sic) relieved himself
of that responsibility and just come right out and told everybody about it . . .its a little late.
TAFT replied, Sounds like he was in good company.969Giusto commented that Im not sure
that anybody had much detail except for a couple of people.
When asked what GIUSTOs relationship was with Neil GOLDSCHMIDT, GIUSTO replied he
did not have a personal relationship with GOLDSCHMIDT; that it was an arms-length
relationship. When asked if GOLDSCHMIDT indicated he was upset with GIUSTO when he
was going out with GOLDSCHMIDTs wife, GIUSTO stated, no.970
964
Ex A74a, p 27
Ex A74a p 28
966
Ex A74a, p 30
967
Ex A74a, p 31
968
Ex A74a, p 32
969
Ex A74a, p 33
970
Ex A74a, p 34
965

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Caller Phil made a statement that he believed GIUSTO was dancing all over the place, not
answering TAFTs questions and avoiding everything she was saying. GIUSTO asked if Caller
Phil had a question and he stated that he did not, that he only wanted to make a comment.
971
TAFT asked one more question of GIUSTO, if he had ever received help from
GOLDSCHMIDT such as a phone call on his behalf or advice. GIUSTO stated he had not and
he had earned his accomplishments on my merits. End of interview.
971
Ex A74a, p 35

Investigation #2
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108.
Chaplain Alice TATE Interview Questions
Background
TATE and GIUSTO know one another. GIUSTO introduced TATE to STELLE and asked
STELLE to interview TATE for the position of a volunteer chaplain. KIMs complaint is that
GIUSTO and TATEs relationship led to STELLE having his working conditions changed, to his
detriment.
1. Are you currently working for Sheriff GIUSTO or MCSO?
2. What is your position with MCSO
3. Have you ever been a full time employee
4. When did you first become a volunteer for MCSO
5. How did you become a volunteer, were you invited by another individual
6. If so, whom and when
8. Has your relationship changed
9. If so, how and why
10. Did you and GIUSTO have any discussions about your work as a chaplain with MCSO
11. If so, what was the content and when did they occur
12. At any time did GIUSTO make any promises or provide you any expectations for work
at MCSO
13. If so, what were they and when did the discussions occur
14. Were there any other discussions that you and GIUSTO had regarding your work at
MCSO
15. What was your understanding of your position, or your future at MCSO
16. Is that still you understanding today
17. Do you believe that all of your expectations were fulfilled regarding your chaplaincy
or work with MCSO
18. If not, how so
19. Is there any thing else that we should know about this matter
109.
Chaplain Alice TATE Interview Summary
On August 2, 2007, PARSONS conducted a telephone interview with TATE. The purpose of the
interview was to determine the relationship between GIUSTO and TATE and if GIUSTO made
any promises to TATE for employment or other benefits.
When KIMs allegation was explained to TATE, she asserted she was an unpaid volunteer who
worked with women inmates.972 TATE stated she was a seminary student and that STELLE does
not work with women inmates, that he works with officers and staff, and that he has never
worked with the female inmates.973
972
973
Ex A 38b, p 2
Ex A38b, p 3

Investigation #2
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TATE stated she was good friends with GIUSTO and that he has male friends but that doesnt
make news, does it. TATE stated that there were a lot of people jealous of GIUSTO and that he
has not helped her, but he has hindered her.974 TATE stated she had worked 31 years for
Pacific Corps and she is going to be starting at the hospital. TATE asserted she is good friends
with GIUSTO but she does not need him to get her a job anywhere. TATE stated she is
completing her degree so that she can work with women. 975
TATE inquired about the investigation and whether it was going to be in the newspaper.
PARSONS told TATE that everything would be open to discovery.976 PARSONS reminded
TATE that the scope of the investigation was focusing on allegations against GIUSTO.
TATE stated that GIUSTO did introduce her to STELLE when GIUSTO was the Chief of
Gresham Police Department and that STELLE did get her the job, but that she works, for free,
with women inmates where STELLE does not work.977
974
Ex A38b, p 4
Ex A38b, p 6
976
Ex A38b, p 7
977
Ex A38b, p 9
975

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110.
Vicky THOMPSON Interview Questions
1.
2.
3.
4.
5.
6.

7. If so, what
8. If not, why not
things
111.
Vicky THOMPSON Interview Summary
On October 4, 2007, PARSONS and KING conducted a telephonic interview with Vicky
THOMPSON. THOMPSON confirmed that she had been a Gresham city councilwoman when
GIUSTO was the Chief of Police; from 1999 to the end of 2002. When presented with the
allegation that GIUSTO had obtained personal gain from his friendship with a city
councilwoman, THOMPSON stated that she and GIUSTO have been friends for years, but I
assure you he didnt get any special favors because hes a friend of mine . . .I dont do things that
way.978
978
Ex A71c, p 2-3

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112.
MCSO Deputy Jose TORRES Interview Questions
Background
TORRES was named by RITCHIE as the individual who wrote the initial letter containing
allegations against GIUSTO
3. DPSST has received information that prior to the KIM complaint, you wrote or sent a
similar list of complaints against GIUSTO to the County Commissioners office
4. Did you do so
5. If not, do you know who did
6. If so, whom did you share the complaint letter with
9. If not, do you know who knows Robert KIM
10. If so, are there other sources and if so, who are the.
11. Would you be willing to submit to a polygraph examination about your knowledge of
the complaint letter prior to KIMs letter, and or of whether you know Robert KIM

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113.
MCSO Deputy Jose TORRES Interview Summary
On August 2, 2007, PARSONS and KING interviewed TORRES, at his place of employment.
TORRES had his Union representative, Todd SHANKS, present with him.
After a review of his employment history, TORRES was asked if he had sent a letter
complaining about the county. TORRES stated, I dont know what youre talking about.979
TORRES asked for a break to speak to his Union representative. TORRES and SHANKS were
reminded that this was not a union matter, the break was granted.
OFF THE RECORD
BACK ON THE RECORD
TORRES wanted clarification regarding the letter that he was asked about. PARSONS clarified
it was the letter that had been faxed to the county commissioners about one year ago. When
asked if TORRES was the source of the faxed letter to the county commissioners, he stated, I
would have to say no comment on that. And I have no other information after this regarding that
matter.980
When asked if TORRES knew KIM, he stated he did not, nor did he know who knows KIM.
When asked if TORRES knew anyone who may have taken information from the faxed matter to
use as a basis for their information, TORRES stated he did not.
When asked if TORRES would be willing to take a polygraph about the specific question of
whether he knows KIM, TORRES stated, absolutely.981
979
Ex A52a, p 2
Ex A52a, p 4
981
Ex A52a, p 4
980

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114.
Angela VALDEZ, Willamette Week
contact us.

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115.
Senator Vicki WALKER Interview Summary

On November 1, 2007, PARSONS and KING met with Senator Vicki WALKER for
the purpose of fact finding relating to her conversation with GIUSTO prior to a
Senate hearing regarding his reappointment to the Tri Met Board. WALKER said she
was furious that the governor would put GIUSTO up for re-appointment when
GIUSTO was denying knowledge about GOLDSCHMIDTs rape of a 14-year old
child. WALKER said that GIUSTO had been in an intimate relationship with the
former governors wife and she believed Margie GOLDSCHMIDT would have
shared details with GIUSTO about why she was unhappy in her marital relationship
why she would go to the step of having an intimate relationship with someone else
while she was married. 982
WALKER said she was angry that the Oregonian referred to the GOLDSCHMIDT
story as an affair rather than rape. WALKER stated it was she who gave the
information to Nigel JAQUISS, Willamette Week, having received a document from
Phil STANFORD from the Portland Tribune about the conservatorship arrangement
with Neil GOLDSCHMIDT victim.983
WALKER said JAQUISS continued to work on the story and to keep in touch with
her. WALKER said she was affected by the GOLDSCHMIDT crime because she
too was a sexual abuse survivor. When JAQUISSs story came out, WALKER
stated she stayed in the background because she had been hammering away at
GOLDSCHMIDT on other issues and neither JAQUISS nor the Willamette Week
would reveal their source.984
WALKER said she was also angry because, after GOLDSCHMIDT had been
revealed, there were those who wanted to forgive him because he had done great
things for the State of Oregon. Then, the governor wanted to appoint
GOLDSCHMIDT to the Higher Ed Board. WALKER said that both GIUSTO and
KULONGOSKI had press conferences saying they knew nothing about what
GOLDSCHMIDT had done. WALKER said she was outraged by the very
political and powerful people in Oregon who knew about GOLDSCHMIDTs crime
and said nothing.985 It was then WALKER decided to be identified as the source.
WALKER said that the Willamette Week story came out and it took her six months
to heal; many of her colleagues were angry with her. When asked if there was
something that made her think GIUSTO had information about GOLDSCHMIDTs
rape, WALKER referred to Fred LEONHARDTs statement and said she had spoken
with LEONHARDT on the telephone after his story was in the Oregonian.986
982
Ex A77a, p 4
Ex A77a, p 4
984
Ex A77a, p 6
985
Ex A77a, p 8
986
Ex A77a, p 9
983

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WALKER said that GOLDSCHMIDT was mayor in the 1970s and governor in the
1980s, yet GIUSTO was just talking about the statute of limitations987
WALKER could not recall if she or if GIUSTO set up their meeting, but she did take
notes of the meeting. WALKER said the on August 6, 2004, meeting lasted two
hours. WALKER characterized GIUSTO as a very good liar and said he took
great pains to look her in the eye and face; he was very direct. WALKER also
thought GIUSTO was trying to charm me . . . that was not working. WALKER
said that GIUSTO asserted he had not met, seen or talked to the victim and, his only
obligation was to find other victims.988 WALKER said GIUSTO asserted he had no
obligation to report it, that he only knew about the settlement and that it involved a
female and it was a long time ago.989
WALKER said she asked GIUSTO when the law was changed to a six-year
extension for reporting sexual abuse and she does not recall his answer to that direct
question, but GIUSTO said it was not his responsibility under the law to do
anything.990 WALKER said GIUSTO then told her about his views of victims and
domestic violence.
Referring to her notes regarding Margie discussion, WALKER said that she asked
GIUSTO a series of questions and believed she asked if he was having a relationship
with Margie. WALKER said GIUSTO told her in that the mid 90s, there was a
civil suit with a woman, a response which had nothing to do with whether he had a
relationship with Margie. WALKER said GIUSTO told her it was unethical to go
beyond rumor and then GIUSTO began to explain he could be tough on crime,
referring to how GIUSTOs own nephew was arrested and sent to prison, at
GIUSTOs insistence.991
WALKER said GIUSTO then began to explain how she and he could work
together.992 Referring to her notes, WALKER said, Bernie also told me that he
could have someone arrested based on suspicions, et cetera, and then release them.
And that while they may be innocent, it would likely leave doubt in the publics
mind. WALKER went on to explain, And my note to myself was, I saw this as a
very subtle threat. WALKER said GIUSTO brought this up out of the blue.
WALKER said that she viewed GIUSTOs comment as a threat and contacted law
enforcement after her meeting with GIUSTO, asking for protection.993
WALKER cited examples of incidents which had occurred to her vehicle after the
GOLDSCHMIDT story came out. When asked if GIUSTO was looking directly at
987
Ex A77a, p 10
Ex A77a, p 11
989
Ex A77a, p 11
990
Ex A77a, p 12
991
Ex A77a, p 13
992
Ex A77a, p 14
993
Ex A77a, p 15
988

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her when he made the statement regarding having someone arrested, WALKER said
GIUSTO was. When asked if she asked GIUSTO what the statement meant,
WALKER did not recall.994 WALKER described her efforts to ensure her
protection.
When asked if she asked GIUSTO at any time where he learned the information
about the sex abuse, WALKER said she did not write that down; that she took
limited notes during her two hour meeting. When asked if she recalled
independently from her notes what some of her discussion with GIUSTO was,
WALKER commented, I was almost certain that I would have asked him had he
had a conversation with Margie GOLDSCHMIDT about the child. . .because after
all, he was in a relationship with her.995
When asked if she asked GIUSTO if he had been in a relationship with Margie
GOLDSCHMIDT during the time he was driving [for Neil GOLDSCHMIDT],
WALKER thought she must have asked him because GIUSTO said it had nothing to
do with whether he had a relationship with Margie.
Regarding GOLDSCHMIDTs crime, WALKER said GIUSTO told her, It was
rumor, Senator. . . I couldnt report rumor.996 WALKER described her efforts on
child abuse and sex abuse in the legislature. WALKER expressed her anger about
people in positions of power and authority who have the opportunity to do positive
things. WALKER said she felt GIUSTO had an opportunity to investigate those
issues and didnt.997
In follow-up, investigators asked WALKER about her statement that GIUSTO said
his only obligation was to find other victims and if that meant GIUSTO was
acknowledging that particular rumor. WALKER stated that was the question that it
raised in my mind, that if hes thinking about finding other victims, then there must
have been one victim. WALKER said she thought GIUSTO was contradicting
himself; that GIUSTO knew what was going on and didnt say anything.998
WALKER said she made it clear to her leadership that she would not support
GIUSTO in his confirmation hearing.
When asked about GIUSTOs reference to knowing that the statute of limitations
was no longer an issue, WALKER stated, He had to have known that [when the
abuse had taken place] because how could you calculate the statute of limitations had
run?.999 WALKER commented about child victims who do not report because of
thinking that the abuse is normal.
994
Ex A77a, p 16
Ex A77a, p 18
996
Ex A77a, p 19
997
Ex A77a, p 20
998
Ex A77a,p 21
999
Ex A77a, p 22
995

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When asked by investigator PARSONS if WALKER would characterize the 13 or 14
year old girl who has been abused as a sexual predator, WALKER stated she
would not. Using her own experiences as a child victim of sexual abuse, WALKER
explained how adults can manipulate children.1000 WALKER asserted that it is not
the fault of the child, but that of the adult. WALKER explained the long-lasting
impact of such abuse, using herself as an example.1001 WALKER spoke of
GOLDSCHMIDTs victim and the difficulties that victim had experienced, and the
inequities of how political leaders are treated when they violate the law, versus other
people.1002
WALKER asserted that as a police officer GIUSTO had an obligation to make
inquiries when he learned [of the crime] but he didnt do it. In a follow-up question,
investigator KING asked if GIUSTO explained to WALKER why GIUSTO believed
GOLDSCHMIDTs rape of a child was not a crime, since it had not been reported,
and since there was a civil settlement. WALKER recalled that GIUSTO said the
matter was settled but that it did not matter to her if there were a civil settlement. 1003
WALKER also said she did not approve of secret or confidential settlements with
government officials and that people need to know why their government is being
sued.1004
When asked about WALKERs contact with LEONHARDT, WALKER said she
spoke with him on the telephone and through emails. When asked if LEONHARDT
shared with her any details that were not in the newspaper, specifically the victims
name, WALKER stated, Fred knew her name.1005 When asked if LEONHARDT
told her where he got the victims name, WALKER stated, I dont think so.
WALKER said she never said the victims name to anyone, believing it to be
inappropriate to do so.1006 When asked if, in her mind, LEONHARDTs knowledge
of the victims name lent credibility to his assertions, WALKER stated said, yeah .
. . if he knew the girls name, he had to know some details because it wasnt as
Bernie always says or someone says, some girl, some time, some long ago
event.1007
WALKER reviewed her notes and email correspondence regarding GIUSTO and
identified a legal case which she thought could apply to GIUSTO and commented,
Because I was trying to figure out a way to get Bernie.1008 WALKER also
referenced her notes of her communication with LEONHARDT dated November 16,
2004. Within the notes are the victims name and a number of assertions by
1000
Ex A77a, p 24
Ex A77a, p 25
1002
Ex A77a, p 26
1003
Ex A77a, p 27
1004
Ex A77a, p 26
1005
Ex A77a, p 29
1006
Ex A77a, p 30
1007
Ex A77a, p 31
1008
Ex A77a, p 32
1001

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LEONHARDT.1009 WALKER reviewed other documents in her file which included
the rules committee agenda and a letter from GIUSTO to WALKER after their
meeting which concluded, If you need any assistance with the issues we discussed
surrounding child abuse, I would be happy to help you in any way.1010
1009
1010
Ex A77a, p 33-36
Ex A77a, p 37

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116.
MCSO Kathy WALLIKER Interview Summary
On August 9, 2007, PARSONS and KING interviewed WALLIKER at her place of

employment for the purpose of fact finding regarding his knowledge of the KIM
allegation.
After a review of her employment background, WALLIKER was asked about her
involvement in the JEDDELOH CHL application process. WALLIKER said GRAHAM
came to her advising JEDDELOH was applying for a permit and that he was to be given
expedited preference in the processing but not making exceptions to the process.1011
WALLIKER stated she turned the application over to a staff person with instructions to
move the application to the top of the list. WALLIKER stated the staff person brought
to her attention there was something on JEDDELOHs record that would disqualify him
from receiving the CHL. This information was taken to GRAHAM.
When asked what was on JEDDELOHs record that would have precluded him from
getting a license, WALLIKER stated JEDDELOH had a DUII diversion. When asked if
WALLIKER saw the permit application after GRAHAM had it, WALLIKER stated that
GRAHAM came to them and stated, The sheriff had approved to give him a concealed
handgun permit. WALLIKER stated she and GRAHAM had a discussion and that
GRAHAM stated he had discussed it with the sheriff and the shiariff said to give
JEDDELOH a permit. WALLIKER recalled the sheriffs approval notated on the
application.1012
When WALLIKER was asked if she ensured that GRAHAM had advised GIUSTO there
was a problem with the application, WALLIKER stated that GRAHAM confirmed
GIUSTO knew about the problems.1013 WALLIKER stated a staff peson called the
JEDDELOH residence and left a message on the answering machine about the permit.
WALLIKER stated a couple days later GRAHAM stated JEDDELOH was not getting the
permit. WALLIKER stated that at some pont she thought GRAHAM came back and got
the JEDDELOH CHL application file, but it was now in the concealed handgun office.1014
When asked if WALLIKER was ever in the presence of GIUSTO when he was apprised of
the criminal background for JEDDELOH, she stated no, all of her conversations were with
GRAHAM.1015
1011
Ex A61a, p 3
Ex A61a, p 5
1013
Ex A61a, p 6
1014
Zx A61a, p 7
1015
Ex A61a, p 8
1012

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Sgt. Ned WALLS Interview Questions
Background
WALLS was named by CHRISTIAN as his supervisor in the unit he and McGILL worked in
when CHRISTIAN jumped the chain of command to report GIUSTOs contacts with McGILL.
1.
2.
3.
4.

I understand that your son has battled leukemia , how is he doing
During the time that your son was quite ill, Sean CHRISTIAN went to Lee GRAHAM
about an issue regarding Deirdre McGILL
5. Did his jumping the chain of command create any hard feelings between you and Sean
or within the unit
6. Were you aware that Deirdre had requested to handle the matter herself
7. Are you aware that Sean initially denied having gone to management about the issue
when confronted by Deirdre
8. Do you feel comfortable relying upon Seans credibility knowing that he was
untruthful with a member of the team
9. Does Sean have credibility with other members of the team
10. Were you aware that Sean CHRISTIAN knew the identity of the person who sent the
complaint to Commissioner Naito and had not provided that information to his superior
officers
11. Has he since provided you with that information
14. Any thing else you would like to add

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117.
MCSO Sgt. Ned WALLS Interview Summary
On August 9, 2007, PARSONS and KING interviewed WALLS, at his place of employment.
After a review of his employment history, WALLS was asked if he worked in the same unit as
CHRISTIAN and McGILL. WALLS affirmed he did. When WALLS was asked if he was
aware of something going on between GIUSTO and McGILL, WALLS stated that McGILL had
told him she was worried GIUSTO was going to hit on her. McGILL said nothing had
happened yet and when WALLS asked her if she wanted him to talk to GIUSTO, McGILL had
told him no, that she wanted to handle it herself. WALLS stated, the next thing I knew . . .Sean
had run down and told Lee Graham. After that McGILL had to talk to HR.1016
When asked if CHRISTIAN had come to his supervisor, WALLS, before he went to GRAHAM,
WALLS stated that CHRISTIAN did not and that McGILL had told him individually and the
whole unit she wanted to take care of it herself. When asked who was present at the meeting,
WALLS identified CHRISTIAN, among others.1017
When asked if there was any reason CHRISTIAN would have taken this personal matter upon
himself to go against McGILLs wishes and go over WALLS head to the Chief Deputy,
WALLS stated that CHRISTIANs assessment was different than his and CHRISTIAN believed,
something really bad was going to happen.. . he wanted to squash it. When asked why
CHRISTIAN wanted to squash it as opposed to allowing McGILL to take care of it as she had
requested, WALLS stated he had no idea. WALLS stated that as a result of CHRISTIANs
actions the harmony of the unit was disrupted for a while. When asked if McGills irritation
with CHRISTIAN was legitimate, WALLS stated it was completely warranted.1018
When asked if WALLS recalled McGILL telling the unit that she had been contacted by HR and
wanting to know who it was that had told someone about her, WALLS did recall that meeting.
When asked if CHRISTIAN had admitted to McGILL and his peers that it was he who had done
it, WALLS stated CHRISTIAN did not admit it at the meeting but later went to McGILL and
admitted to it. When asked to clarify if CHRISTIAN was specifically at the meeting, WALLS
was not positive.
When asked if WALLS was aware that there was a period of time when CHRISTIAN did not say
it was he who had contacted management about McGILL and only at a later time that he
admitted it, WALLS stated his recollection was that it was the same day or the next day.1019
When asked about McGILLs reaction, WALLS stated McGILL was upset with CHRISTIAN
for quite a while, an extended period of time. WALLS stated that he does not think
1016
Ex A55a, p 3
Ex A55a, p 4
1018
Ex A55a, p 6
1019
Ex A55a, p 8
1017

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CHRISTIAN ever apologized to McGILL, which kind of extended itself. WALLS was unsure
if CHRISTIAN and McGILL still had a strained relationship; each of them do their jobs.
When asked if CHRISTIAN ever explained to his sergeant why he didnt use the chain of
command, WALLS stated GIUSTO had an open door policy. WALLS stated he was not
irritated at that but at the fact that CHRISTIAN had disregarded McGILLs wishes.1020
When asked if WALLS knew KIM, he stated he did not, nor did he know anyone who knew
KIM. WALLS was unsure if he had ever seen KIMs letter.1021
When asked about his personal opinion of CHRISTIANs credibility, WALLS stated as a police
officer he had excellent credibility. When asked if CHRISTIAN were to have told
investigators that TORRES was the one who wrote the letter, if that would be a credible
statement, WALLS stated he believed so; he trusted CHRISTIAN with his life.
1020
1021
Ex A55a p 10
Ex A55a p 11

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118.
Brent WALTH, Oregonian
contact us.
On June 13, 2007, Brent Walth and Jeff Mapes of The Oregonian reported, Giusto told the
Oregonian that he doesnt remember talking specifics with Leonhardt but may have discussed
vague rumors in 1989 . . .1022
1.
2.
3.
4.
5.
6.
7.
8.

Confirm the author
and if retained
9.
1022
Ex A12.99

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Kimberly WILSON, Oregonian
contact us.

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119.
MCSO Deputy Tim WONACOTT Interview Questions
Background
WONACOTT was named as a possible witness to McGILLs assertions that she could handle
GIUSTOs contacts and that she wanted to handle them on her own.
1.
2.
3.
4.
5.
6.
How long have you worked for MCSO

What positions have you served in
Are you aware that McGILL had concerns about GIUSTOs contact with her
If so, what did she tell you
Did she tell you or your co-workers that she wanted to handle the matter on her own
Are you aware that at some point HR Director OTT came to speak with her about the
matter
7. If so, after this meeting with OTT did McGILL contact you or the members of your
unit
8. If so, what did she say
9. Did McGILL ask who had not abided by her wishes to handle the matter on her own
10. Was Sean CHRISTIAN at this meeting or during this discussion
11. Did he, or anyone else, tell her at the meeting that he was the one who had disclosed
the information to management
12. If so, has CHRISTIANs actions, contrary to McGILLs wishes, affected the working
relationship of the unit
13. If CHRISTIAN did not initially disclose it was he who contacted management when
confronted, has this affected the trust within the unit
16. Do you know anyone who may have distributed a similar complaint letter
approximately one year ago.
120.
MCSO Deputy Tim WONACOTT Interview Summary
On August 2, 2007, PARSONS and KING interviewed WONACOTT, at his place of

employment. The purpose of the interview was fact-finding regarding his knowledge of KIMs
allegations.
After a review of his employment history, WONACOTT was asked if he was aware of concerns
McGILL had regarding GIUSTO. WONACOTT stated he was aware that McGILLs concerns
included GIUSTO coming around more often when McGILL came into the unit. When asked if
WONACOTT recalled McGILL saying something to the unit as a whole, he could not recall.1023
1023
Ex A53a. p 3

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WONACOTT characterized McGILL as never appearing worried or nervous about it and
McGILL never indicated she was concerned about GIUSTOs attention. WONACOTT recalled
that he had heard, secondhand, that people offered to run interference for her, but McGILL
declined.1024
When asked if he was aware that someone decided to make a complaint on behalf of McGILL,
WONACOTT could not recall. When asked if WONACOTT recalled McGILL confronting the
members of his unit and asking if they had made a complaint against her wishes, WONACOTT
could not recall. WONACOTT stated he did not know KIM nor anyone that knows KIM.
1024
Ex A53a, p 4

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121.
Roger WOOD Interview Questions
Background:
According to LEONHARDT, the victims mother told WOOD that Neil GOLDSCHMIDT had
sexually abused her daughter. WOOD then confronted GOLDSCHMIDT and forced him to tell
Margie GOLDSCHMIDT.
1. Describe your relationship with Neil
2. How has this relationship changed with the changing roles
3. How did you first become aware that Neil may have had a relationship with a young
woman other than his wife Margie
4. Who told you
5. When did they tell you
6. What did they tell you
7. What did you do with this information
8. Did you have a conversation with Neil about what you had been told
9. When you had this conversation, did Neil admit or deny it
10. At some point during the conversation was the decision made to tell Margie
11. Who made this decision
12. When were you first aware that Margie had been told about Neils relationship with the
young woman
13. Who told you
14. Did you ever become aware that GIUSTO also had knowledge of the relationship
between Neil and the young woman
15. If so, when did you become aware of this, and who told you
16. Do you know GIUSTO
17. If so, when did you first meet him
19. Has your relationship changed with your changing roles
20. When is the last time GIUSTO and you communicated
122.
Roger WOOD Interview Summary
On August 1, 2007, WOOD called DPSST and spoke with KING. WOOD identified himself as
Margie [GOLDSCHMIDTs] brother.1025 WOOD stated that there was one thing he wanted to
clear up. WOOD stated that he had read in the newspaper that he was reported to have told
Neil GOLDSCHMIDT to confront the issue with the girl. WOOD stated, I just want to make it
really clear that I have never had any conversation with Neil whatsoever about that incident or
situation.
When asked if Mrs. Dunham had come to him and confided in him that her daughter and Neil
had this relationship, WOOD stated, I dont want to discuss anything . . .in regard to anybody
about any of that.
1025
Ex A50a, p 2

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123.
David YADEN Interview Questions
Background
YADEN was GOLDSCHMIDTs advisor and was the former head of the states Energy
Department. Unknown if he was a go-between, between GOLDSCHMIDT and victim and/or
her mother.
3. What was your position in his administration and related duties
4. How long did you work for him
5. Have you ever met GIUSTO
7. If so, describe your relationship with GIUSTO
8. Has it changed with the changing roles
13. In your opinion, what was the relationship between GIUSTO and GOLDSCHMIDT
14. Prior to the disclosure by the media of GOLDSCHMIDTs misconduct, did you have
any prior knowledge of any information relating to the misconduct,
15. If so, how, who, when
16. How long did he know LEONHARDT, how, relationship, was LEONHARDT in a
position to be a confidant of GOLDSCHMIDT or GIUSTO
17. Have you ever met the victims mother?
19. Describe your relationship with the victims mother
20. Where did the victims mother work, was it in state or city government?
21. If so, did she work in the GOLDSCHMIDTs administration at any time

Investigation #2
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124.
David YADEN Interview Summary
On July 30, 2007, PARSONS and KING interviewed YADEN in a telephone conversation. The
purpose of the interview was fact-finding to determine what first hand knowledge he had of
GOLDSCHMIDTs crime and who knew of it.
PARSONS advised YADEN that the focus of the investigation was on GIUSTO and information
he knew from GOLDSCHMIDT. YADEN denied any involvement as a go-between
GOLDSCHMIDT and the victim. YADEN asserted he did not know about GOLDSCHMIDTs
crime until it was revealed in the newspaper.1026
YADEN characterized his relationship with GOLDSCHMIDT as political, not social, nor would
he have been invited to everything GOLDSCHMIDT was invited to. YADEN characterized
GOLDSCHMIDT as one who would compartmentalize people based on what he needed or
wanted.1027
When asked if YADEN knew GIUSTO, he stated he saw GIUSTO a fair amount at Mahonia
Hall or on trips. When asked if YADEN became aware that GIUSTO was having a relationship
with Margie GOLDSCHMIDT, YADEN said he did not and it was not his character to be tuned
into that sort of stuff.1028
YADEN stated he worked pretty closely with LEONHARDT, who was a speechwriter. YADEN
characterized his relationship with LEONHARDT as friendly but professional.1029
When asked if YADEN would find LEONHARDTs summation of his knowledge of
GOLDSCHMIDT and the young girl credible, YADEN stated that he never heard a thing or had
a hint from LEONHARDT that he was privy to something like that.1030 YADEN felt that
LEONHARDT always wanted to be a bigger player than he was. YADEN identified
LEONHARDT as part of the inner circle during the GOLDSCHMIDT administration, along with
IMESON and DODSON.1031 YADEN stated KULONGOSKI floated in and out.
When asked if GIUSTO took part or was present for policy making decisions, YADEN stated,
Not that I saw. YADEN did not know the relationship between GIUSTO and LEONHARDT,
nor did he know if GIUSTO socialized with KULONGOSKI. When asked if he believed
LEONHARDT got along with everyone, YADEN recalled that it seemed to be pretty
harmonious.1032 When asked if there was ever a time that YADEN questioned LEONHARDTs
truthfulness, he stated he could not recall anything.1033
1026
Ex A48a, p 4
Ex A48a, p 6
1028
Ex A48a, p 7
1029
Ex A48a, p 8
1030
Ex A48a, p 9
1031
Ex A48a, p 10
1032
Ex A48a, p 12
1033
Ex A48a, p 13
1027

Investigation #2
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1/16/2008

When asked when YADEN discovered that GIUSTO and Margie GOLDSCHMIDT were having
a relationship he stated it was after Neil GOLDSCHMIDT made the announcement he was not
going to run again.1034
When asked if he saw any changes after he was aware of GIUSTO and Margie
GOLDSCHMIDTs relationship, or whether GIUSTO continued to be Neil GOLDSCHMIDTs
driver, YADEN could not recall.1035 YADEN did recall there was a change of drivers at one
point.1036
When asked if he was aware of KIMs allegation, YADEN said he had not looked at it closely,
and again stated he had not been involved in any way.
1034
Ex A48a, p 14
Ex A48a, p 17
1036
Ex A48a, p 18
1035

Investigation #2
Page 296 of 302
1/16/2008
125.
Debbie YOUMANS Interview Questions
Background
According to an anonymous email received by MINNINS, YOUMANS was a confidant of Helen
BICART and may have knowledge GOLDSCHMIDTs crime if GIUSTO told BICART.
1.
2.
3.
4.
5.
6.
7.
8.
9.
126.
How long have you known Helen (Foster) BICART?

Describe your relationship with her
Were you aware that Helen was involved in a friendship with GIUSTO
If so, what did you understand her relationship to be with him
Did she ever tell you about GIUSTO telling her that he had knowledge of a
relationship between Neil GOLDSCHMIDT and a young woman?
When did you first learn about this relationship
When you leaned about it, did you and Helen ever discuss the matter
If so, what did you discuss
Do you have any additional information that you think we should know
Debby YOUMANS Interview Summary

On August 8, 2007 PARSONS and KING conducted a telephone interview with
YOUMANS for the purpose of fact finding. When asked if Helen (Foster) BICART had
ever discussed with her GIUSTOs knowledge of Neil GOLDSCHMIDTs crime,
YOUMANS stated that BICART never knew anything about it. YOUMANS stated that
she and her former husband go way back with Bernie and that she did not want to
know any thing positive or negative about him; she did not want to be associated with
him. End of conversation.

Investigation #2
Page 297 of 302
1/16/2008
127.
Les ZAITZ, Oregonian
contact us.

Ex A12.32) Giusto said Thursday that he had been unaware of allegations of domestic violence
when he signed the license.
(ExA12.116) In February 2005, Giusto approved Jeddelohs application for the concealed
handgun permit. He later said he had done so before learning Jeddeloh had a drunken driving
conviction. . . In a July 23, 2005, interview with The Oregonian, Giusto was asked about
traveling to Seattle with Doss in May 2005. I didnt take a trip to Seattle, he said.
1.
2.
3.
4.
5.
6.
7.
8.

Confirm the author
and if retained
9.

Investigation #2
Page 298 of 302
1/16/2008

I. INDEX
A
Alice TATE 34, 99, 100, 111, 274
ANDERCHUCKI 14
ANGLEMIER 8, 12, 13, 14, 25, 92, 93, 95, 96, 97, 101,
102, 103, 104, 105, 106, 107, 108, 111
DPSST 7, 8, 9, 10, 14, 17, 18, 19, 25, 39, 40, 43, 44, 45,
47, 59, 61, 62, 63, 64, 65, 66, 71, 72, 76, 77, 78, 83, 85,
86, 87, 88, 89, 90, 91, 114, 115, 116, 123, 139, 142,
165, 167, 170, 176, 177, 193, 195, 197, 198, 199, 200,
203, 205, 208, 209, 215, 223, 224, 233, 242, 249, 260,
264, 268, 277, 279, 289, 290, 293, 298
DPSST Investigator 17, 19
Driggs 25, 92
DUNCAN 15
B
E
Bernard GIUSTO 222
BICART 7, 14, 30, 94, 95, 111, 113, 297
Bobby ODONNELL 35, 44, 100, 111, 240, 255, 256
BOTTOMLY 36, 103, 114
Brady issues 25, 106, 107
Brady Issues 13
BRANT 14, 37, 104
Brent RITCHIE 35, 44, 112, 131, 255, 256
BROWN 26, 27, 68, 69, 70, 71, 75, 135, 171
BUDNICK 14, 35, 102, 116
BURDICK 14
BURTSHAELL 14
BUTTS 14, 37, 61, 106, 112
F
FRANCESCONI 15
Fred LEONHARDT 17, 29, 33, 94, 111, 143, 160, 166,
201, 211, 212, 213, 214, 215
chaplain 64
Chaplain 21, 64
CHL 8, 25, 26, 39, 66, 75, 101, 105, 135, 136, 172, 173,
185, 186, 236, 253
CHRISTIAN 14, 98, 101, 125, 126, 127, 128, 129, 175,
227, 228, 236, 286, 287, 288
Christine KIRK 35, 99, 111, 206, 207
Christy LEONHARDT 33, 166, 211, 212, 213
Clackamas County District Attorney 34, 186
Code of Ethics 11
CORTADA 14, 34, 41, 42, 98, 99, 101, 111, 130, 131,
132, 137, 174, 251, 252, 253
D
Dave RADER 34, 41, 98, 111, 131, 244, 251, 252
David YADEN 35, 99, 111, 294, 295
Deirdre McGILL 35
Diana OLSEN 35, 45, 112, 129, 242, 253
DMV 23, 37, 92
DODSON 14, 34, 97, 119, 133, 187, 189, 216, 295
DOJ 8, 9, 18, 26, 27, 29, 37, 66, 68, 69, 70, 73, 75, 76, 81,
82, 86, 93, 94, 95, 96, 98, 101, 105, 147, 185, 199, 202
DOSS 7, 15, 16, 37, 39, 66, 76, 77, 78, 79, 80, 81, 84,
106, 107, 112, 134, 136, 138, 162, 173, 174, 185, 186,
194, 201, 202, 203, 235, 236, 237, 238

Investigation #2
Page 299 of 302
Ed STELLE 34, 97, 111, 146, 266

ELLIOTT 26, 36, 69, 75, 76, 101, 105, 112, 128, 131,
137, 138, 140, 141, 155, 237
ENGWEILER 26
ESTEVE 15, 36, 102, 139, 221, 222
1/16/2008
Garr NIELSEN 34, 112, 128, 235

GATES 15, 26, 98, 101, 111, 137, 140, 141, 207
GECKLER 28
GEDDES 15, 36, 102, 142
GEISTWHITE 37, 104
GIUSTO 1, 7, 8, 9, 10, 12, 13, 15, 16, 24, 25, 26, 27, 28,
29, 30, 31, 33, 36, 37, 39, 40, 41, 42, 43, 44, 45, 46, 47,
48, 49, 50, 51, 52, 53, 54, 55, 56, 57, 59, 60, 61, 62, 63,
64, 65, 66, 67, 68, 69, 70, 71, 72, 73, 74, 75, 76, 77, 78,
79, 80, 81, 82, 83, 84, 85, 86, 87, 88, 89, 90, 91, 92, 93,
94, 95, 98, 101, 104, 106, 108, 109, 111, 112, 113, 117,
118, 119, 121, 122, 123, 124, 125, 126, 127, 128, 129,
130, 131, 132, 133, 134, 135, 136, 137, 138, 140, 141,
143, 147, 148, 149, 150, 151, 152, 153, 154, 155, 156,
157, 158, 159, 160, 161, 163, 164, 165, 166, 167, 168,
169, 170, 171, 172, 173, 174, 175, 177, 179, 180, 181,
182, 183, 184, 185, 186, 187, 188, 189, 190, 191, 192,
193, 194, 195, 200, 201, 202, 203, 204, 206, 207, 208,
209, 210, 211, 212, 213, 214, 215, 216, 217, 218, 219,
220, 221, 222, 224, 225, 227, 228, 229, 230, 231, 232,
233, 234, 235, 236, 237, 238, 239, 241, 242, 244, 246,
247, 248, 250, 251, 252, 253, 257, 258, 259, 262, 263,
265, 266, 267, 269, 270, 271, 272, 273, 274, 275, 276,
277, 280, 281, 282, 283, 285, 286, 287, 288, 291, 292,
293, 294, 295, 296, 297
GLYNN 15
GOLDSCHMIDT 7, 14, 16, 17, 22, 31, 39, 46, 51, 52, 53,
54, 55, 56, 59, 94, 99, 100, 102, 103, 113, 117, 118,

119, 120, 121, 122, 123, 133, 134, 138, 144, 145, 148,
149, 150, 151, 152, 157, 159, 160, 163, 165, 166, 167,
168, 171, 174, 179, 180, 181, 182, 183, 184, 187, 188,
189, 190, 191, 192, 193, 194, 195, 201, 208, 209, 210,
211, 212, 213, 214, 215, 216, 217, 218, 219, 220, 221,
238, 293, 294, 295, 297
GRAHAM 15, 26, 27, 34, 41, 42, 60, 62, 66, 67, 68, 69,
70, 71, 72, 73, 74, 97, 101, 102, 107, 125, 126, 127,
128, 130, 131, 132, 135, 137, 146, 152, 153, 154, 155,
156, 162, 171, 172, 173, 174, 175, 229, 237, 238, 241,
247, 248, 251, 252, 253, 256, 259, 266, 285, 286, 287
GREEN 16, 36, 102, 176
Gregg KANTOR 31, 94, 102, 112, 133, 182, 187, 188,
215
Gresham 9, 15, 17, 18, 21, 39, 60, 98, 124, 126, 136, 137,
138, 147, 171, 172, 173, 174, 197, 201, 203, 222, 229,
230, 235, 239, 275, 276
Gresham Police Department 9, 60
H
HASLER 16, 35
HINKLEY 37, 104, 105, 106, 179, 180, 181
I
IMESON 16
Investigative Team 8, 23, 24, 36, 43, 44, 45, 46, 47, 48,
56, 57, 59, 61, 62, 63, 64, 65, 66, 67, 73, 74, 75, 76, 77,
78, 79, 80, 84, 85, 86, 87, 88, 89, 90, 91, 93, 94, 95, 96,
97, 98, 99, 100, 101, 102, 103, 104, 105, 106, 107
J
Jacquenette McINTIRE 34, 111, 229, 230
JAQUISS 16, 36, 102
Jay PENTHENY 35, 102, 112, 249, 250
JEDDELOH 7, 8, 16, 26, 27, 28, 29, 32, 34, 39, 40, 66,
67, 68, 69, 70, 71, 72, 73, 74, 75, 76, 79, 81, 82, 83, 84,
93, 96, 100, 101, 102, 111, 134, 135, 136, 137, 138,
140, 141, 147, 154, 155, 156, 158, 162, 171, 172, 173,
185, 186, 202, 203, 206, 207, 231, 236, 237, 238, 258,
259, 285
Jeff GATES 35
Jennifer OTT 31, 62, 112, 127, 201, 247, 248
Jose TORRES 35, 100, 111, 127, 277, 278
K
KALBERG 26, 28
KANTOR 16
Kathy WALLIKER 35
KATZ 16
KENNEDY 30, 31, 97, 98, 111, 118, 119, 192, 193, 195
KIM 7, 15, 17, 23, 31, 32, 36, 37, 40, 41, 44, 45, 59, 60,
61, 62, 64, 65, 66, 75, 76, 77, 78, 85, 86, 87, 88, 91, 92,

Investigation #2
Page 300 of 302
93, 95, 97, 99, 100, 101, 104, 106, 111, 112, 118, 119,
126, 128, 129, 131, 132, 136, 137, 138, 141, 158, 159,
162, 171, 172, 173, 177, 178, 196, 200, 201, 202, 203,
204, 205, 207, 224, 227, 228, 229, 231, 232, 233, 235,
236, 237, 240, 241, 242, 243, 244, 245, 247, 248, 250,
252, 253, 255, 256, 257, 259, 262, 263, 274, 277, 278,
285, 287, 288, 291, 292, 296
KING 8, 12, 13, 17, 23, 24, 25, 26, 29, 30, 31, 32, 33, 34,
35, 36, 37, 57, 91, 92, 93, 94, 95, 96, 97, 98, 99, 100,
101, 102, 103, 104, 105, 106, 107, 108, 111, 118, 122,
126, 127, 128, 129, 131, 137, 141, 148, 151, 156, 158,
159, 165, 170, 172, 177, 179, 183, 186, 188, 193, 194,
195, 200, 205, 207, 208, 211, 213, 215, 222, 224, 227,
233, 237, 239, 244, 248, 250, 252, 256, 259, 263, 276,
278, 287, 291, 293, 295, 297
KIRK 17
KOK 34, 98, 101, 102
KULONGOSKI 15, 17, 36, 40, 86, 87, 103, 104, 112,
117, 118, 119, 123, 143, 145, 166, 170, 189, 190, 192,
208, 209, 210, 211, 212, 213, 214, 215, 218, 219, 220,
221, 295
KYLE 17
1/16/2008
Law Enforcement Data System 7

LEDS 7, 18, 19, 24, 25, 31, 40, 91, 95, 96, 97
Lee GRAHAM 34, 97, 111, 130, 171, 172, 175, 233, 248,
251
LEONHARDT 7, 17, 29, 33, 49, 50, 51, 52, 53, 54, 55,
56, 57, 93, 95, 96, 97, 99, 100, 111, 117, 118, 119, 121,
122, 133, 143, 144, 145, 148, 149, 150, 157, 158, 160,
161, 163, 164, 165, 166, 167, 170, 179, 181, 182, 183,
184, 187, 188, 189, 190, 192, 193, 194, 195, 208, 209,
210, 211, 212, 213, 214, 215, 216, 217, 218, 219, 220,
221, 222, 269, 270, 271, 272, 280, 283, 293, 294, 295
LEONHARDT, Christy 17
LIM 17
LORANCE 13, 17, 23, 36, 92, 93, 94, 96, 97, 103, 104,
107, 208
LOUGHRAN 26
M
MADDUX 26, 93
MAILIN 18
MAPES 18, 36, 102, 221, 223
Margie 16, 59, 94
Margie GOLDSCHMIDT 16, 31, 39, 59, 97, 98, 99, 111,
119, 144, 163, 165, 166, 167, 168, 183, 189, 191, 193,
194, 195, 201, 209, 210, 211, 212, 215, 217, 218, 219,
221, 222, 293, 295, 296
Mark HERON 35, 102, 112, 177
Marshall ROSS 34, 98, 111, 258, 259
McBETH 18, 27, 28
McCAIN 24, 28, 31, 32, 33, 34, 92, 95, 107, 111, 154,
155, 158, 224, 262, 263
MCCAIN 18
McDADE 18, 202

McGILL 18, 98, 101, 111, 125, 126, 127, 128, 129, 175,
225, 227, 228, 247, 248, 286, 287, 288, 291, 292
McINTIRE 18, 28, 34, 60, 61, 100, 102, 157, 230
MCSO 14, 15, 17, 18, 19, 20, 21, 22, 24, 33, 66, 75, 78
MINNIS 8, 18, 23, 24, 25, 29, 30, 31, 91, 92, 93, 94, 96,
97
MOYER 18, 252, 266
Multnomah County District Attorney 20, 29, 88, 95, 199,
204
Multnomah County District Attorneys Office 88
Multnomah County Sheriffs Office 19, 20
MUSGRAVE 26
N
Naito 286
NAITO 7, 19, 29, 30, 43, 93, 100, 103, 112, 177, 232,
233, 234, 249, 250
Ned WALLS 35, 112, 128, 286, 287
NEFF 27, 28
Neil GOLDSCHMIDT 16, 31, 59, 95, 97, 98, 111, 113,
117, 118, 121, 122, 123, 133, 144, 160, 163, 165, 166,
167, 168, 169, 170, 187, 189, 191, 193, 194, 195, 201,
212, 213, 215, 216, 217, 218, 219, 220, 221, 293, 294,
296, 297
NIELSEN 34, 101, 106, 107, 235, 237, 238
NOAH 19, 37, 60, 61, 106, 112, 239
113, 118, 122, 123, 126, 131, 137, 141, 148, 150, 151,
156, 157, 158, 159, 161, 165, 167, 172, 175, 177, 179,
183, 186, 188, 200, 203, 204, 205, 207, 211, 215, 222,
227, 230, 233, 237, 239, 244, 248, 250, 252, 256, 259,
266, 274, 275, 276, 278, 287, 291, 295, 297
Paugh 232
PAUGH 7, 19, 30, 233
PELLEGRINI 28
PERKINS 26
R
RADER 19, 26, 34, 41, 42, 45, 98, 101, 131, 132, 137,
146, 152, 153, 174, 237, 242, 244, 245, 251, 252, 253
Rafael CORTADA 35
Reese 20
REESE 20, 36, 103, 208
Restraining Order 25
RITCHIE 20, 44, 103, 132, 240, 255, 256, 257, 277
Robert BURTCHAELL 35
Robert KIM 23, 91, 92, 126, 130, 135, 140, 177, 196, 205,
206, 226, 232, 235, 240, 242, 247, 249, 251, 255, 258,
277, 286, 291
Roger WOODS 35
ROSS 20, 26, 28, 101, 137, 141, 207, 258, 259
S
O
OCONNELL 19, 24, 44
ODONNELL 19, 44, 240, 255, 256, 257
OAR 259-008-0010 9, 11, 29
OAR 259-008-0060 11
OAR 259-008-0070 9, 11, 29
OLSEN 19, 35, 45, 101, 105, 129, 242, 244, 245, 246,
251, 253
Oregon Department of Justice 8, 9, 21, 26, 86, 194
Oregon State Police 9, 34, 144, 184, 191
ORS 131.005 12
ORS 131.105 12
ORS 131.125 12
ORS 131.155 12
ORS 166.291 9, 13, 25, 29
ORS 181.630 11
ORS 181.640 9, 11
ORS 181.662 9, 11
ORS 206.010 13, 29, 96
ORS 206.345 13
ORS 419B.010 12
OSP 9, 34, 98, 145, 197
OSWALT 19, 202
OTT 19, 62
P
PARSONS 8, 19, 29, 30, 31, 35, 37, 83, 93, 94, 96, 97,
98, 99, 100, 101, 102, 104, 105, 106, 107, 108, 111,

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1/16/2008
SANDERS 20, 35, 102, 260

SCHRUNK 26
Sean CHRISTIAN 35, 62, 98, 111, 125, 126, 173, 227,
228
Senator BURDICK 35, 100, 102, 112
SHANKS 20
SHEIFFER 26
SHRUNK 20, 76
SIMMONS 20, 33, 96
SKYE 21, 208
SORIANO 28
standard of proof 11
STANFORD 20, 35, 36, 102, 264
statute of limitations 12, 25, 95, 96, 97, 103, 123, 144,
165, 222
Statutory Rape 25
STELLE 21, 64
STONE 17
SULZBERGER 21, 36, 102
T
TATE 21, 64, 99, 101, 274, 275
Thomas IMESON 31, 94
THOMPSON 21, 37, 60, 61, 106, 112, 157, 276
Tim MOORE 35
Tim WONACOTT 35
Todd SHANKS 34, 91, 97, 111, 278
Tom GIUSTO 30, 222
TORRES 21, 101, 128, 129, 234, 277, 278, 288

Truthfulness and Public Safety Professionals Court
Decisions 13, 107
TWEEDT 8, 21, 24, 26, 30, 32, 93, 94, 95, 96, 98, 100,
101, 102, 103, 104, 105, 108
WILSON 21, 36, 102, 290

WONACOTT 22, 101
Y
V
VALDEZ 21, 36, 102, 279
YADEN 22
YORK 22, 33, 96, 99
YOUMANS 8, 22, 30, 94, 97, 98, 99, 101, 102, 111, 297
WALLIKER 26, 69, 70, 102, 112, 155

WALLS 22, 101, 286, 287, 288
WALTH 21, 22, 36, 102, 289
WIEDEN 28
ZAITZ 22, 36, 102, 298

Investigation #2
Page 302 of 302
1/16/2008

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DPSST Investigation #1 - GIUSTO

Bernard GIUSTO DPSST# 07617

DPSST Investigation #1 - GIUSTO

Bernard GIUSTO DPSST# 07617

DPSST Investigation #1 - GIUSTO

Bernard GIUSTO DPSST# 07617

DPSST Investigation #1 - GIUSTO

INVESTIGATIVE ACTIONS TAKEN ............................................................................... 92

Bernard GIUSTO DPSST# 07617

DPSST Investigation #1 - GIUSTO

OSP (ret.) James HINKLEY Questions.......................................................................... 179

Bernard GIUSTO DPSST# 07617

DPSST Investigation #1 - GIUSTO

Bernard GIUSTO DPSST# 07617

DPSST Investigation #1 - GIUSTO

Bernard GIUSTO DPSST# 07617

DPSST Investigation #1 - GIUSTO

Bernard GIUSTO DPSST# 07617

DPSST Investigation #1 - GIUSTO

Bernard GIUSTO DPSST# 07617

DPSST Investigation #1 - GIUSTO

5. Investigative Team Discussion and Findings

Bernard GIUSTO DPSST# 07617

DPSST Investigation #1 - GIUSTO

DPSST Investigation #1 - GIUSTO

Conduct that is prejudicial to the administration of justice;

Oregon Revised Statute statute of limitations

Oregon Revised Statute mandatory reporting sexual abuse of child

Criminal conduct, as affected by the statute of limitations

Bernard GIUSTO DPSST# 07617

DPSST Investigation #1 - GIUSTO

ORS 206.010 ORS 206.345 General duties of sheriff. 15

ORS 166.291 The criteria for issuance of a Concealed Handgun License.

ORS Impact of revocation on currently elected sheriff.17

Legal Definition of Corroboration, Corroborate

Bernard GIUSTO DPSST# 07617

DPSST Investigation #1 - GIUSTO

503 378 2214

Legal Services Coordinator

4190 Aumsville Hwy SE

503 310 1631 Cell

MCSO Corrections Union

503 969 5714

Former chief of Lake

5205 NE Barnes Road

2940 NE Klickitat Street

503 288 3146

Portland, Oregon 97212

503 244 1444 Office

503 284 8976

Former Gresham City

4641 SW Dosch Road

6605 S.E. Lake Road

1548 SE 11th Street

503 251 2451

503 251 2451 Office

DODSON, Ruth Ann

503 297 4856

Portland, Oregon 97221

Bernard GIUSTO DPSST# 07617

DPSST Investigation #1 - GIUSTO

503 988 6161

503 221 1116 Residence