IN THE CIRCUIT COURT OF THE STATE OF OREGON

FOR THE COUNTY OF JOSEPHINE

EDWARD SNOOK,
Plaintiffs
v.
)
DEBORAH SWAN,
Defendant

)
)
)
)
)

Court No. 14CV0835

CA Appeal 162319
CA Appeal 161582

)
)
)

AMENDED MOTION FOR EXTENSION OF TIME

TO CORRECT TRANSCRIPT
Defendant respectfully submits its Motion to Correct the Transcripts
for Appeals A162319 and A161582, the above titled cause before the
Honorable Thomas Hull, Circuit Judge, in the Circuit Court of the State of Oregon,
for Josephine County, The November 12, 2014, transcript has 142 errors that need
to be corrected. (see pages 3 through 11). The June 12, 2015, transcript has 25
errors that need to be corrected. (see pages 12 through 13) The July 14, 2015
transcript has 28 that need to be corrected. (see pages 14 through 15 ) The Oct. 16,
2015 transcript has 2 errors that need to be corrected. (see page 16 ) The
December 21, 2015 transcript has 90 errors that need to be corrected. (see pages
17 - 24) Filed on July26
4, 2016 by Deborah Swan
Page 1 of 24

/s/ Deborah Swan

CERTIFICATE
PROOF OF SERVICE
I certify that on the 26
4th day of July, 2016, the original foregoing
AMENDED MOTION TO CORRECT TRANSCRIPT was deposited in the United
States Post Office at Spring, Texas ,with first class Priority Mail postage prepaid
thereon addressed to:
Appellate Court Administrator
Appellate Courts Records Section Records Section
1163 State Street
Salem OR 97301-2563
I certify that on the 26
4th day of July , 2016, I electronically filed and served
copies of the foregoing AMENDED MOTION TO CORRECT TRANSCRIPT by
electronic service to opposing council James Leuenberger at
jim@fights4rights.com. I also sent by USPS Priority mail a hard copy to the
following address:
James Leuenberger
Attorney for the Plaintiff
5200 Meadows Rd..Suite 150
Lake Oswego, OR
I further certify that on the 4th
26day of July, 2016 the foregoing AMENDED
MOTION TO CORRECT TRANSCRIPT was deposited in the United States Post
Office at Spring,Texas ,with first class Priority Mail postage prepaid there on
addressed to the Transcript Coordinator and the Trial Court Admin by to the
following address:
Josephine County Circuit court
500 NW 6th Street
Grants Pass, OR
Deborah Kay Swan
self represented litigant
Defendant - Respondent

Page 2 of 24

Nov 14, 2014 Defendant's Motion to Vacate - Set Aside

Page
Line
To Be Corrected
Correction
4

to make (inaudible)

to make judicial

on (inaudible)

record

(inaudible)

judgment

11

(inaudible)

60

17

(inaudible)

Well Im having

23

(inaudible)

docket that has been

filed. So this is self
authenticated evidence
that has been filed.

(inaudible)

filed by James
Leuenberger

(inaudible)

the first motion he put in

10

last (inaudible)

page 18-25

11

Leuenberger claims I

11

(inaudible)

or answered

12

I did

But I did

13

through both

to both

6.

13

court

court clerk

13

(inaudible)

as well as James on time

13

So I wish to file

This default judgment is

void

Page 3 of 24

Page

Line

To Be Corrected

Correction

20

is the one (inaudible)

is aware that I filed it on

time

21

Joe

Lisa

22

(inaudible)

received a copy of it

(inaudible)

records

(inaudible)

the 2nd

December

the

7.

(inaudible)

or answers

(inaudible)

any intent of me trying to

appear and that is completely
not true.

22

(inaudible)

its there in your records too

23

tracking, which

tracking, with the proof of his

notary

(inaudible)

implication that I

There

It

(inaudible)

entered

10

(inaudible)

Thank you.

12

(inaudible)

to show you

14

(inaudible)

James

Page 4 of 24

Page

Line

To Be Corrected

24

(inaudible)

Default

25

(inaudible)

sworn affidavit

10

(inaudible)

the clerk.

10

(inaudible)

Pursuant to

10

13

(inaudible)

this to be false

10

16

(inaudible)

judgment

10

17

(inaudible)

page 2 line one

10

19

appearance.

10

21

(inaudible)

21-23

10

23

(inaudible)

or made any appearance.

10

24

appearance

2014

10

24

(inaudible)

submits a misleading
affidavit

10

25

(inaudible)

failed to disclose

10

25

the facts regarding

the facts of my
appearance

11

(inaudible)

is his notary

11

notarized

she notarized

11

the false

this false

Page 5 of 24

Correction

Same appearance. The same

Page

Line

To Be Corrected

Correction

11

(inaudible)

sworn

11

(inaudible)

knowing it was false

11

default

11

(inaudible)

2014

11

(inaudible)

sent to the office of

11.

same thing,

same thing, he is
claiming that I did not
appear.

11

accepted it

accepted it knowing it to
be

11

(inaudible)

false

11

10

(inaudible)

you Judge Hull

11

11

(inaudible)

due to

11

13

(inaudible)

for this

11

14

(inaudible) default

knowing all this to be

false

11

16

(inaudible)

for 50,000.00

11

16

(inaudible)

9% intrest

11

18

(inaudible)

rules

11

19

by (inaudible)

and applied to this

default judgment.

Page 6 of 24

Page

Line

To Be Corrected

Correction

11

20

filed

followed

11

21

(inaudible)

owe any attorney fees

12

guess

get

12

(inaudible)

procedure

12

that

facts

12

(inaudible)

has gone beyond the

allegations of this
complaint

\
12

(inaudible)

that I even owe

12

10

(inaudible)

and misrepresentation of facts

17

(inaudible)

I would like to state there has

been no deception

17

(inaudible)

right when I realized a

typographical

17

11

(inaudible)

an error on my part

17

15

(inaudible)

I was able

17

19

(inaudible)

that you could make sure you

get both

17

21

(inaudible)

but theres the facts that I sent

to the

17

21

court

clerk

Page 7 of 24

Page

Line

To Be Corrected

17

24

ruled on,

ruled on, Im not sure what the

hold up is on making my

18

(inaudible)

18

of

and

18

(inaudible)

and

18

(inaudible)

notary

18

11

default

the false

18

13

(inaudible)

default judgment is the same

day he received the answer

18

21

(inaudible)

to?

18

22

(inaudible)

Can you look at it please?

22

25

(inaudible)

and its very concerning to me.

23

court,

court, at

23

11

(inaudible)

assumption

23

23

(inaudible)

told me and Ive got the

recorded conversations and the

24

(inaudible)

that when the judge sees there

is an attempt to make

24

(inaudible)

is being made to answer

24

(inaudible)

and appear

Page 8 of 24

Correction

Page

Line

To Be Corrected

Correction

24

(inaudible)

Judge reads the little note that

she says she put on there the
judge most likely will not enter
a default.

24

15

from my parents

from my parents claiming I

24

17

(inaudible)

delay

24

18

(inaudible)

before she

24

19

(inaudible)

application approved

24

20

(inaudible)

to her and she told me

24

21

(inaudible)

now its Thursday and I

am

24

22

if I still thinking

still thinking i have

24

23

(inaudible)

time

24

24

(inaudible)

first time

25

25

(inaudible)

of faxing

25

(inaudible)

allowed to be faxed

25

(inaudible)

Her and I got into a little

bit

I did, that was (inaudible) I had just got done

reading the rules

Page 9 of 24

Page

Line

To Be Corrected

Correction

25

(inaudible)

confrontation on the
phone

25

Lisa said well,

Lisa said Deborah,

25

(inaudible)

bills

25

10

(inaudible)

dynamics

25

14

(inaudible)

a violation of my rights
of due process

25

17

did not hold me

should not hold me

25

17

with the (inaudible)

from being able to step

25

18

(inaudible)

a claim against me

25

19

(inaudible)

and thats what this

whole thing has turned
into.

26

20

(inaudible)

and my own due process

25

22

(inaudible)

appellate judges

25

22

(inaudible)

also there is lots of

26

(inaudible)

he did get my answers

26

15

(inaudible)

the clerk to, to appear

26

17

(inaudible)

thing to do. In the

matter of justice.

Page 10 of 24

Page

Line

To Be Corrected

27

27

21

(inaudible)

28

16

falsely (inaudible)

28

17

(inaudible)

28

19

On the order

28

21

submit anything else?

attempts

142 errors total

Page 11 of 24

Correction
submit anything else?
After the hearing?
the other opposing side
falsely state
any intent of my
appearance?
On every one of these
orders
intent

June 12, 2015

Plaintiff Special Motion to Strike Anti Slap
Oral Argument
Page

Line

To Be Corrected

17

stand

stay in

20

list

lift

21

list

lift

13

list

lift

50

21

(inaudible)

57

21

listed

lifted

60

Anti-Slagg

Anti-Slapp

70

13

No you have to first say

the motion

70

16

you know

to show

71

22

(inaudible)

answer, affirmative
defense or counter claim

74

(inaudible)

He never responded timely

83

(inaudible)

Whats been

86

17

(inaudible)

extraordinary

87

(inaudible)

No.

88

(inaudible)

very

88

writing

ruling

116

22

(inaudible)

Dyer

Page 12 of 24

Correction

Everything

Page

Line

To Be Corrected

121

10

(inaudible)

OKC

122

18

(inaudible)

a fact

123

12

(inaudible)

hearsay

124

the four

before

126

19

(inaudible)

libel

128

(inaudible)

bombings

128

(inaudible)

lunatic

142

14

(inaudible)

affirmative
defense

25 errors total

Page 13 of 24

Correction

July 14, 2015

Plaintiff Summary Judgment Oral Argument
Page

Line

To Be Corrected

Correction

31

14

(inaudible)

specifically

31

17

(inaudible)

Ms. Swan

32

15

(inaudible)

makes Mr. Snook

33

(inaudible)

tort

37

11

(inaudible)

US Observer

40

19

(inaudible)

evidence

41

(inaudible)

special

41

16

Snook

Swan

44

21

(inaudible)

on todays hearing

49

10

(inaudible)

prove

56

10

abatable

debatable

57

(inaudible)

response

59

17

(inaudible)

threatened

62

(inaudible)

movant

62

10

(inaudible)

affirmative defense

62

25

(inaudible)

put on the

63

(inaudible)

have a case

Page 14 of 24

Page
64

Line
14

To Be Corrected
(inaudible)

70

(inaudible)

exposing

70

11

(inaudible)

all evidence

76

20

(inaudible)

a valid complaint

84

12

(inaudible)

defamation

90

(inaudible)

pro se

92

(inaudible)

video

93

(inaudible)

those are

101

24

hasn't asked

has asked

102

20

(inaudible)

object

108

(inaudible)

your the gatekeeper

28 errors total

Page 15 of 24

Correction
pre litigation

Defendants Motion for Summary Judgment

October 16, 2015
Page

Line

108

21

135

22

To Be Corrected

I will just simply motions

to reconsider
(inaudible)

2 errors total

Page 16 of 24

Correction

I will just simply ignore

motions to reconsider
pro se litigant

Page

Line

Courts Hearing
December 21, 2015
To Be Corrected

140

11

(inaudible)

so you want me to explain what

happened that morning? Is that
what you want me to start off
with?

140

16

(inaudible)

its my right to be heard

140

19

(inaudible)

of these objections

140

19

(inaudible)

that morning

140

20

(inaudible)

this has never happened before

140

20

(inaudible)

have never had any issues

140

21

(inaudible)

dont know why

140

23

(inaudible)

and I did make objections to the

hearing

140

24

(inaudible)

and go over. We can just start

off with the objections that I
have already made from the
hearing that y'all already had

140

25

(inaudible)

If you dont want to give me

another hearing.

141

(inaudible)

the orders that he proposed

141

14

(inaudible)

as well as what

141

16

(inaudible)

which month now

Page 17 of 24

Correction

Page

Line

To Be Corrected

141

21

(inaudible)

142

I filed the motions

I filed a motion

142

There's a list of all the

I filed a motion with a list

142

(inaudible)

needs to be heard are this

whole list of all these
objections.

142

(inaudible)

things that have not been heard

142

24

going further

from service

142

25

(inaudible)

when I picked

143

(inaudible)

I contacted the

143

12

(inaudible)

recorded

143

13

look for yourself

listen for yourself

143

21

(inaudible)

James

143

24

court

clerk

143

24

called the

talked to the

143

25

court

clerk

143

25

back that morning

Page 18 of 24

Correction

you said during the last

hearing

contacted the clerk that

morning

Page

Line

To Be Corrected

144

144

(inaudible)

case.

144

declaration

speculation

144

(inaudible)

I had no idea why my phone

144

(inaudible)

service was interrupted.

144

(inaudible)

I was told by Lisa

144

12

(inaudible)

morning

144

14

department as
well as (inaudible)
tech support

144

24

file (inaudible)

file any proof

144

24

just (inaudible)

just told

145

wanted to

dont even

145

make (inaudible)

act as if I was

145

putting in

submitting

145

(inaudible)

what your

145

13

(inaudible)

I was not aware

told (inaudible)

Correction
told Lisa, when I got
ahold of her through
Skype my computer
phone

department if you
want me to
submit that to the
court I can.

Page 19 of 24

Page

Line

To Be Corrected

145

21

actual, the no respond,the

(inaudible) phone

145

22

voice,voice mail (inaudible)

that keeps coming up

145

22

just says

doesnt say

145

23

and I

phone was disconnected at

that time.

146

I got on (inaudible)

my Skype phone

146

on the (inaudible)

on the computer

146

my (inaudible)

my time

146

so this (inaudible)

so this was ya know so yall's

146
was

you all can hear it

I think its 45 minutes long

yalls hearing was only I think

its only 45 min long

146

(inaudible)

scheduled

146

11

in touch (inaudible)

in touch once I realized what

was going on with on my end

146

16

call (inaudible)

call and my phone was not

working

147

(inaudible)

actually
Page 20 of 24

Correction
when yall were trying to dial my
phone number. You can hear the

Page

Line

To Be Corrected

147

is when (inaudible)

is what Lisa told me

147

13

(inaudible)

10 minutes after

147

24

didn't (inaudible)

didn't hear a

148

problem the court

phone call from the court

148

i didn't (inaudible)

i didn't, my phone was not working

148

20

And so that ...

And so thats when I requested

149

(inaudible)

Houston, TX

149

14

phone (inaudible)

phone with no.

151

22

Yeah. (inaudible)

Yeah. I would like to add

152

proof of it

proof of this.

152

in fact

the Skype

152

to put up

to set up

152

10

152

11

everything,

everything fixed and

152

12

and (inaudible)

and with this situation

152

13

the

just a

152

14

(inaudible)

10 dollars

Correction

all this

Page 21 of 24

152

15

tell you the (inaudible)

send you the proof

Page

Line

153

21

(inaudible)

your honor

154

19

your (inaudible)

granting

154

20

the (inaudible)

orders he proposed

154

25

rules of (inaudible)

rules of UTCR

155

(inaudible) universal

universal trial court rules

155

(inaudible) and I would have

if he would of conferred with

me first

155

and I would have (inaudible)

then I would easily been able to

send him Mr. Leuenberger

155

him cuz

the

155

155

To Be Corrected

Correction

proof of all the (inaudible)

violation of his (inaudible)

Page 22 of 24

proof of all the stuff that he is

demanding to have proof of
violation of these proposed
orders that he has put in are
not even valid

Page

Line

155

(inaudible) the court (inaudible) followed the court rules

under the 5.160 condition
under 5.100 submission of

155

(inaudible)

155

10

To Be Corrected

Correction

orders (inaudible) proposed orders

the court. So I (inaudible)

the court. So I want

for that to go on the
record.

155

25

this to be (inaudible)

this to be listed

156

this is (inaudible)

this is you

156

So (inaudible)

So you already admitted

this is a complex case

156

and file (inaudible)

a motion

90 errors total

Page 23 of 24

LEFT BLANK

Page 24 of 24