FAX To: CIVIL CLERK Company: JOSEPHINE COUNTY CIRCUIT COURT Fax Number: 5414712079 Re: SNOOK VS SWAN 14CV0835 Comments: PLEASE FILE AND ENTER IN COURT RECORDS HARD COPY SENT IN THE MATL AND COPY SENT AND FAXED TO OPPOSINC ATTORNEY LEUENBERCER, ‘THANKS, DEBORAH SWAN Facsimile Transmittal From: DEBORAH SWAN Date: ta/14/2014 Pages: 28 (including cover)IN THE CIRCUIT COURT FOR THE STATE OF OREGON FOR THE COUNTY OF JOSEPHINE EDWARD SNOOK Plaintiff, v DEBORAH K. SWAN, Defendant, ‘CASE NO: 14CV0835 ORDER §31.150 SPECIAL MOTION TO STRIKE This SPECIAL MOTION TO STRIKE ORDER having come before the Court upon the DEFENDANT Deborah Swan. The Court having reviewed the evidence and being oth- erwise fully advised in the premises, it is ORDERED AND ADJUDGED that this SPE- CIAL MOTION TO STRIKE all granted denied 2. The Court finds the following legal authority in support of this Order. DONE AND ORDERED this __ day of __. 2014 Copies to: DEBORAH K. SWAN 1318 CHESTERPOINT DR SPRING, TX 77386 JAMES LEUENBERGER P.O.BOX 1684 LAKE OSWEGO, OR 97035, Page 1 of 27IN THE CIRCUIT COURT OF JOSEPHINE COUNTY FOR THE STATE OF OREGON IDWARD SNOOK Cace No: 14CV0835 Plaintiff, vs. DEBORAII SWAN Defendant §31.150 SPECIAL MOTION TO STRIKE 1. Pursuant to Statute Or. Rev. Stat. §31.150, Defendant Deborah Swan hereby moves the Court to dismiss Plaintiff's Complaint with prejudice. The bases for this Motion are set forth in the accompanying Memorandum. Dated this 11th day of December, 2014. 2. By and through Defendant’s motion, Defendant Swan seeks an order striking all Plaintiff's claims against her and dismissing Swan’s actions on the grounds that Swan can fall within the scope of Oregon's anti- SLAPP statute (Or. Rev. Stat. 31.150 et seq.) Page 2 uf 27Article I, section 8, forecloses the enactment of any law written in terms directed to the substance of any "opinion" or any "subject" of communication, unless the scope of the restraint is wholly confined within some historical exception that was well established when the first American guarantees of freedom of expression were adopted and that the guarantees then or in 1859, demonstrably were not intended. for each. Examples are perjury, solicitation or verbal assistance in crime, some forms of theft, forgery and fraud and their contemporary variants. Only if a law passes that test is it open to a narrowing construction to avoid “over breadth" or to serutiny of its application to particular facts. State v Robertson, 293 Or 402, 412 (1982). OREGON CONSTITUTION ‘A Moreover, while Ms. Swan had a moral and legal requirement to report Plain- Uiff’s actions of threats and verbal abuse towards her, to the public as well to the average private citizens, to the Plaintiff's outrageous conduct and criminal ac- tivity. B. A similar provision exists in the Oregon Constitution, which is equally applica- ble to Ms, Swan's statements. Page 3 uf 27C."No law shall be passed restraining the free expression of opinion, or restricting the right to speak, write, or print freely on any subject whatever; but every per- son shall be responsible for the abuse of this right.” 31.150 (3) SPECIAL MOTION TO STRIKE; WHEN AVAILABLE; BURDEN OF PROOF. A. Defendant Swan makes this special motion to strike against the Plaintiff’s claim, due to the written statement by the Defendant Swan, is her exercise of constitutional rights of petition, and constitutional Tights of free speech, in connection with a public issue and an issue of public interest. B. Defendant Swan challenges Plaintiff Snook's claims, that Plaintiff's will be entirely lacking in merit and in evidentiary support, that Plaintiff Snook cannot establish any likelihood of ultimately prevailing in connection with any of the asserted “causes of action.” C, _ Plaintiffs Snook Complaint Ariscs Out Of Defendant’s Deborah Swan’s Ex- ercise of her Constitutional Rights of Free Speech and Petition. Page 4 uf 27D. — Aspecial motion to strike a claim in a civil case is proper when the case “arises out of” statements made with the exercise of the constitutional rights of pe- tition and free speech. ORS 31.150(2) A. This is particularly so when the societal interest at issue is significant. B. The privilege rests upon the same idea, that conduct which otherwise would be actionable is to escape liability because the defendant is acting in furtherance of some interest of social importance, which is entitled to protection even at the expense of uncompensated harm to the Plaintiff's reputation. C. The interest thus favored may be one of the Defendant herself, of a third person, or of the geucral public. D. If it is one of paramount importance, considerations of policy may require that the defendant's immunity for false statements be absolute, without regard to her purpose or motive, or the reasonableness of his conduct, E, Prosser, Torts § 114, p 776 (4th ed 1971). ORS 31.150(2)(d) Applies to Deborah Swan’s Statements to Public supporters on You Tube and Others. Page 5 uf 27A.Ms. Swans statements were “other conduct in furtherance of the exercise of her constitutional right of petition in connection with a public issue or an issue of public interest.” ORS 31.250(d). B.Ms. Swan's statements to the public about what Ed Snook, the US Observer was doing to her was an exercise of her constitutional right to petition her grievance that the Plaintiff caused. C. The proof of Plaintiff Ed Snook’s oral abusc, and his threats towards the Defen- dant Deborah Swan, is included in the you Lube Video that Defendant uploaded. to the public. D.The public supporters of Charles Dyer were very interested with the support that the active US Military Soldier, Chris Mortenson, brought in to assist with the post conviction legal battle. E. Chris Mortenson donated $10,000.00 to hire Ed Snook, US Observer to get Charles Dyer exonerated from this 30 year sentence, F. Ed Snook, the US Observer advertises that he has championed 1700 false sex abuse cases and he is the only one who can get Charles Dyer free. Page 6 uf 27G. Therefore all these details clearly proves the activities of Ed Snook, the US Ob- server, and all results involving their investigation in the Charles Dyer’s case, was and still is a public interest. STATEMENTS WERE MADE IN CONNECTION THE WITH A PUBLIC ISSUE AND ARE A PUBLIC INTEREST. A.The high profiled case of Charles Allen Dyer out of Oklahoma, and the US Ob- server is a “public issue” and an “issue of public interest.” B.See, €.g., In Defense of Animals v, OISU, 199 Or App 160, 188 (2005) (“A mat- ter or action is commonly understood to be *in the public interest’ when it affects the community or society as a whole, in contrast to a concem or interest af a pri- vate individual or entity”); C.Black's Law Dictionary 1266 (8th ed. 2004) (defining “public interest" as the “general welfare of the public that warrants recognition and protection" and as "[s]something in which the public as a whole has a stake; Defamatory statements as 4 matter of public concern, because it “was of general interest and was made available to the general public”. Page 7 of 27EVIDENCE OF PUBLIC INTEREST D.Statements made by Ms. swan in her You Tube Video and in related to the events that took place around the U. S. Observer’s case were absolutely privi- leged, 31.150(2)(d), . Ms. Swan must only make a prima facie showing that the action filed by the Defendant’s rose out of alleged statements that constituted “conduct in further- ance of the cxcrcisc of Ms Swan’s constitutional right of petition in connection with a public issue or an issue of public interest.” F. The US Observer , Edward Snook was hired by public supporter by the name Chris Mortenson, who contacted the Defendant Deborah Swan. G. Chris Morteason was active US Army, when he hired Ed Snovk, wo vindicate an unlawful conviction of the high profile case of a former US Marine Charles Dyer. FACTS IN SUPPORT SPECIAL MOTION TO STRIKE 1. The statements Deborah Swan posted public on You Tube, are protected due to her rights off expressing my opinion based on the following first hand experi- ences. Page 8 uf 272. All viewers of the posted video, has an open offer to rebut, or bring information contrary to what is provided in the video. 3. Defendant Deborah Swan was a customer of the US Observer. who experienced the unethical, abusive, and criminal behaviors from the owner Edward Snook. 4, Defendant Deborah Swan’s public comments are protected rights of expressing personal experiences that she had dealing with the US Observer and Ed Snook. MITIGATING CIRCUMSTANCES IN SUPPORT OF DEFENDANT MAKING PUBLIC STATEMENTS A.'On May 26, 2012, Plaintiff Edward Snook, owner of the U.S.Observer, was contacted by an “active duty” United States soldier, who was at the time, de ployed out in Afghanistan. B.Chris Mortenson introduced himself as a friend of Defendant Deborah Swan, who is a supporter of Charles Dyer. 1g defendant making a special motion to strike under the provisions of thie section hag the initial burden of making a prina facie showing that the claim against which the motion is made arses Out of a Statenent, document or conduct described in suDsec- tion (2) of thie section. Tf the defondsnt moots this burden, the burden shifts to the plaintiff in the action to establish chat chere is a probability that the plaintift will prevail on the claim by presenting substantial evidence to support a prira facie case, if the plaintifr meets this burden, the court shail deny the motion. Page 9 uf 27C.Mortenson explained to Plaintiff Snook that he was assisting Defendant Debo- rah Swan, with raising support for the “post conviction” legal battle Charles Dyer, due to the unlawful conviction. D. Due to Charles Dyer’s outspoken views about the Iraq Wars, and his “anti cor- ruption” and “pro constitution” speeches, he became popular on Youtube. E. Charles Dyer’s You Tube channel reached over a million viewers. F. Charles Dyer was also a spokes person for a nationwide organization call “Oath Keepers.” which gained the interest of the public and the main stream media. G.Charles Dyer was aka July 4 Patriot, his popularity caused him to become a “target” for all different reasons. H.Due 10 his vindictive ex wife who has a history of filing false charges, has led Dyer to serving a 30 year sentence for a crime he did not commit. I. Defendant Deborah Swan was a friend of Charles Dyer. Page 10 of 27J. Defendant was working with Charles Dyer, to help raise public support due to the unlawful conviction. K.During the summer of August 2011, Defendant discovered the U. S. Observer's website , and contacted the owner Plaintiff Ed Snook. L.At this time the Defendant did not have the financial means to hire the US Ob- server. M.After conviction in May of 2012, the Defendant Swan was contacted by the ac- tive duty U.S.Solder Chris Mortenson. N. Defendant Swan told the soldier about the US Observer, and that according to the web site of Plaintiff Ed Snook, he offered a 100% money back guarantee, if the US Observer fails at total vindication. (see below) O.The add below from the US Observer web site, where Snook claims he has vin- dicated over 1700 false convictions of sexual abuse. P. Chris Mortenson assigned Deborah as his liaison. Page 11 of 27Q.Plaintiff Ed Snook sent a contract to Deborah Swan. R. Plaintiff Snook received the first payment of $5,000.000 from Chris Mortenson by wire transfer to Edward Snook’s bank account, on May 27, 2012. S. On May 28, 2012, Defendant Swan began to work with Ed Snook, and forward emails with case documents, records, evidence, to Ed Snook, and his lead inves- tigator Lome Dey. T. On June 26, 2012, Defendant Swan spoke with Plaintiff Ed Snook on the phone to get an update for Mortenson on how the case was going. U.Plaintiff Snook told Defendant that they had gone through all the evidence and were ready for the next payment of $5,000.00. ‘V. During the conversation, Plaintiff Ed Snook told Defendant Swan all her infor- mation was helpful, and to forward everything else she has over to their lead in- vestigator. W Plaintiff Ed Snook, complimented Defendant Swan and told her that his lead in- vestigator, Lorne Dey, was impressed with her. Page 12 of 27X.Plaintiff Snook expressed that they both were looking forward to meeting her in Oklahoma. Y. Plaintiff Ed Snook told Defendant that he might need her help out in Oklahoma with getting information. Z. Plaintiff Snook even told Defendant that some of her evidence she has sent to them was enough too get Charles Dyer freed. AA. After the conversation was finished, Defendant Swan felt very confident with how the investigation was going. BB. The following transcription below, is only a section of the conversation be- tween Snook and Swan. CC.The full audio of this conversation, is found in the online You Tube Video where Ed snook, claims is defamatory. DD. Ed Snook manipulated Deborah Swan, by telling her exactly what he wanted her to hear, in order to get another payment of $5,000.00 from Chris Mortenson. Page 13 of 271.Ed 2.Deborah 3.Ed 4.Deborah S.Ed oDeborah T Give that conversation to Loren, Were obviously we're going after new evidence as well, but that Evidence on its own could get him out of prison. I'm just curious to know how you're going to do This. Chris wants to know exactly what you've done, you Figure 50 hours into the case, So what can 1 tell these guys to make them feel like we're going to have Good results? What can I tell them without breaching any security? Um you know.... We've been through every bit of paperwork that has been pre sented. Loren has been through all the videos and everything you've sent to him. We've talked extensively with the mother and the sister and everyone we can talk too without giving away what we're doing. are they talking about, they are more focused along the rape violations and I am more focused of the details about the actual state violations and the FBI Involvement, and all that. But have they gone into depth with you about all the Federal involvement? The death threats and all that kind of stuff? you need to talk to Lorne about this because up until a couple weeks aga T usually only go after new evidence. he prosecutor is the one who these violations 10 this family and that’s why we wanted to get two guys Involved. We all already know he's innocent! We already Know he didn't do this to the little girl! Here's An example, Amy's daughter the FBI came and contacted her and got the daughter to come in and speak to the Feds about Charles . The FBI interrogated her and tried to force her to say or believe that Charles molested her when she was little, and that she just doesn't remember. Trying to get her to admit something that wasn't true. Things like this is concerning. This shows it, it looks like a setup. There are lots of situations like that andI was wanting you guys to look into this... has anyone told you about this fact? Page 14 of 277.Ed 8.Deborah 9.Ed 10.Deborah dLEd That all needs to go to Lorne. Get everything over to Lorne, so we've not missing any information, but we've concluded I think he gave me 27 reasons why and he's not guilty, and a couple reasons why he could be guilty. Then we went back over the back and forth, and we've concluded that he's inno cent. But in order to have all this other stuff is great, there may have been a conspiracy, but still at the end of the day we need to know the facts. But at the end af the day, we're going to go to the heart of it and get new evidence as well. And claim ing that these peuple did these things to him is going to be very helpful to us. But to go file a post-conviction case, we're going to get Charles out of prison a hell of a lot quicker if we have new evidence that shows he did not do it. So you're going after new evidence? in fact you need to go through all this with Lorne. He needs to know everything you know. There is one other thing I want to ask you. I'm sure you are aware of the way the judicial misconchuct and there are certain things that the government will reverse cases like when his right has been violated... Like when you find out the prosecutor lied to the, and the judge does not hold him accountable, and all these things could actually of exonerated Charles, and get a government reversal id someone as yourself... if you can know how to go in and push this through that's why someone like you can do that kind of standing up for Charles right's, like his habeas corpus has been Violated, he never got a fair trial, there's so much.. I'd have to hear the exact examples of the prosecutor, would help... if the prosecutor withheld exculpatory evidence that's grounds for a reversal., the prosecutor caught lying or lied to the jury, that's not grounds to get a reversal, withholding but he needs all your information so we do not miss anything. Page 15 of 27EFFECTS OF MANIPULATION 1, Defendant Swan contacted Chris Mortenson immediately and discussed this conversation. 2. She shared with Mortenson about all the positive feedback that Defendant Swan received about her evidence from Plaintiff Ed Snook. 3, Once Chris Mortenson heard this positive news, he immediately wired the next $5,000.00 payment to Plaintiff Ed Snook. A. After that positive conversation between Plaintiff Snook and Defendant Swan, the very next day, June 27, 2012, Chris Mortenson contacted Ed Snook directly to confirm the $5,000.00 payment was received. 5. Ed Snook confirmed he received the payment and then began to demonize the Defendant Deborah Swan. 6, Plaintiff Ed Snook told Mortenson he refuses to work with Defendant Swan. Ed Snook began to demonize Deborah, claiming to Mortenson that she is a lunatic and most likely on drugs. 7. Edward Snook told Mortenson that Defendant Swan had wasted the first $5,000.00 that he had paid. 8. Plaintiff Snook then told Mortenson he was not going to work with Defendant Swan anymore. Page 16 of 279. Mortenson was confused and contacted Defendant Swan to ask her why Ed Snook told him the opposite from what she just told to him. 10.Defendant Swan was shocked that Ed Snook would do a 180 turn on her. 11. Defendant Swan asked Mortenson to check his email, and to listen to the recording of the positive conversation that she recorded between her and Ed Snook. 12,This is the first full conversation that is in the You Tube video. 13.Swan then asked Mortenson to record any more calls he may have with Edward Snook, so she can hear what all he is saying about her. 14, The same timeframe, Plaintiff Snook began to spread slander to the group of individuals with whom Defendant warned the Plaintiff about. 15.This group has destroyed all efforts of public support over the past 3 years. 16,This group began to falsely accuse Defendant of stealing donation money from Chris Mortenson. Page 17 of 2717.This group was not aware that Mortenson and Swan were in contact daily and were friends. 18.Defendant Swan attempted to contact Plaintiff Ed Snook, about the dis informa- tion that was being spread all over the You Tube support pages of Charles dyer. (example below) 19.Plaintiff Ed Snook was not taking any of her calls nor was he returning any calls. SolPie year ‘00 NOT DONATE TO DEB SWAN: SHE DOES NOT HAVE THE CONTRACT CALL MRS. DVER INSTEADI TH iS THE SAME SCAM THAT EB TRIED TO RUN OVER A ‘YEAR AGO! TIS HOW SHE PAYS FOR LIVING IN MOTELS. CONTACT SWANS FAMILY FOR REAL INFORMATION! THEY CAN RIO LONGER DEAL WITH HER AND HAVE DCEN FORCED TO TURN THOR DACKS ON HCR AT THES POINT, YOUR LIES HAVE GONE ON LONG ENOUGH, SWAN 20.0n July 7, 2012, Defendant Deborah Swan received an email from the lead in- vestigator, telling her she was dropped from the contract and not to contact them any more. 21.The next 2 weeks, Defendant continued to try to contact Ed Snook. Page 18 of 2722.Every time Plaintiff Snook would answer his phone, he would answer and say, “U.S.Observer, Hello, Hello, Hello” acting as if he could not hear the Defen- dant, then hang up the phone. 23.During this time the public slander was being spread around all over the You Tube support page for Charles Dyer, accusing Deborah Swan of stealing money, and the Us Observer dropped her from her contract was now working with the group of people, with whom were the Defendant’s enemies. 24.Plaintiff Ed Snook went to the family and the mother of Defendant's friend Charles Dyer. 25.Plaintiff Ed Snook, told the family that Deborah Swan had wasted all the money that was paid. ‘rome RarTue Seve Sensepabessns; “Tat enrdatensh cannery eres! ‘Subj Corer posted cn ED Expose Chats Dyes spot ‘Seat: Thu San 1 1970 12:00:00 8 You palpate | sma pion | report per |subacibe ¢ Mic ete seoneet FE iin cee 11o know wars goag on fx spoke with Mrs. ye: she ad me the guys US Observer gave the cosas hr bacane thay thought yoo were pry! (Thy mare ig) ny were going give wp the coe booms when they tried to speak about the fats ofthe case, al you could do was rant about novernnent conspiracy! Try cling Stead be. go 8 me eee ot "Ta eoply te hi comment HA le Tosa Anam on ak Page 19 of 2726.Ed Snook turned the mother of Charles Dyer against Defendant, by claiming that he refuses to work with Defendant Swan, and will only work with her. 27.Plaintiff Ed Snook then told the mother that in order to keep the investigation moving forward, he needed more money. 28.Deborah contacted the sister of Charles Dyer and tried to warn her that Ed Snook was just paid $5,000.00, and not to give any more money, but it was too late. 29. The sister had already sent a check to Ed Snook for $3,000.00, and his mother had paid another $6,500.00. 30.Deborah Swan was being publicly destroyed by lies and dis information that was being put out by the US Observer, Ed Snook, to the family of Charles Dyer and the public supporters. 31.Defendant tried to contact Plaintiff Ed Snook, to discuss their contract, to dis- cuss the slander told to Chris Mortenson, and the rumors about dropping her from their contract. Page 20 of 2732.When the Defendant finally got ahold of Plaintiff Ed Snook, he threatened the Defendant, called her a whacked out bitch, denied having a contract with her, and then hung up on her. The following are 2 of the conversations that are also included on in the You Tube public video. PLAINTIFF AND DEFENDANT guly 19, 2012 Snook "U.S. Observer" Swan "you have a contract, a business arrangement with me. you have a contract" Snook "hello" Swan "you Lave @ voulsact will Mele Snook “YOU DON'T TAKE A WARNING VERY EASILY DO YA DEBORAH?" Swan "Excuse me? I'm the customer and you signed a contract with me. We have an agreement. That you had me sign, and you have been running around, slandering me..~ Page 21 of 27Snook Hung up the phone. END OF PHONE CONVERSATION The transcription below, is also from the uploaded You Tube Video. This is the exact dialog between Plaintiff Snook and Defendant Swan, This is sell authenticated evidence of fraud, and theft by fraud, by Plaintiff Ed Snook, denying he had a contract with Defendant, orally abuses the Defendant, and then threatens her. Swan Snook Swan snook CALL BETWEEN PLAINTIFF AND DEFENDANT July 19, 2012 "U.S. Observer" "Did you not call me on Sunday and leave a message for me to call you?” “yes I did.” "So what's the difference between Sunday and now?" "1 waS APPARENTLY returning your calls I assume? And I did not hear you the first 2 times you called, so don't you ever call me up and start talking down to me." Page 22 of 27Swan Snook Snook Swan Snook Swan Snook "Excuse me? ya know I believed in the US Observer.I believed in the U.S. Observer and I brought you to them, and you have slandered and defamed to all these people.... and made up complete siander "DEBORAH YOUR A WHACKED OUT BITCH! YOUR A WHACKED OUT BITCH, AND DON'T CALL ME AGAIN! I DON'T WANNA TALK TO YOU! DO YOU UNDERSTAND THAT! "No, I do have a contract with youn! Okay.. "NO YOU DON'T HAVE A CONTRACT WITH ME YOU STUPID BITCH!" "and my friend has just paid you $10,000.00 and y' all have scam me” "NO YOU DON'T HAVE A CONTRACT WITH ME YOU STUPID BITCH! AND IF YOU WANT A HARD TIME, I WILL GIVE YOU A HARD TIME!" "Are you threatening me?" HUNG UP PHONE END ON CONVERSATION Page 23 of 27 + <+33.The self authenticated evidence of this outrageous behavior, can be listened to and watched on the public You Tube Channel of Defendant Deborah Swan. 34.Deborah recorded all of her conversations she had with Ed Snook and his inves- tigator Lome Dey. 35. Three of these conversations have been uploaded to YOU TUBE, to share with the public and the supporters of Charles Dyer. 36.Ed Snook has committed theft and fraud against Deborah Swan by deceit. 37.The original motive for the Defendant to recorded her conversations, was for Chris Mortenson, to be able to listen to the progress and the details of how the U. S. Observer's involvement with the case was coming along. 38. These recording have ended up exposing the US Observer, and Edward Snook, by their own outrageous behaviors, which is self evidence that Ed snook did de- fraud, threaten, slander, and cause injury to Defendant Deborah Swan’s reputa- tion and character. Page 24 of 27Enforceability of Oregon's Anti-SLAPP Statute in this Court The Ninth Circuit generally apply and enforce state anti-SLAPP statutes, see Newsham, 190 F.3d at 972-973, including in particular Oregon's anti-SLAPP scheme, see Northon, 637 [F.3d at 938-939, Englert, 551 F.3d at 1101-1102 Wherefore Defendant Swan moves this court to properly apply or enforce the procedural mechanisms of Oregon's anti-SLAPP statute. A Defendant Swan challenges Plaintiff Snook's claims, that Plaintiff’s will be so entirely lacking in merit and in evidentiary support that Plaintiff Snook cannot establish any likelihood of ultimately prevailing in connec- tion with any of the asserted “causes of action.” B.Video itself exhibits the evidentiary support of the evidentiary statements by Deborah Swan. C. The Plaintiff has failed to claim that anything in the video is false. D. In any event Plaintiff Suook’s claims do not fall within the scope of the statnte, and Section 31.150 challenge, then this case is dismissed, relief is, Page 25 of 27granted and damages awarded to the Defendant from the Plaintiff Ed Snook, and the attorney James Leuenberger. CERTIFICATE OF SERVICE/MAIL I Deborah Swan, on December 11, 2014, have served by faxed and USPS mail, a true copy to James I enenherger, who is the attorney of Fd Snook, at the address below. Thave also served by fax and by USPS mail, the original to Cheryl Shonk who is the civil clerk at Josephine County Oregon, for her to stamp and file the original into the public case records. JOSEPHINE COUNTY JAMES LEUENBERGER 500 NW 6TH STREET 5200 SW MEADOWS RD. GRANTS PASS, OR LAKE OSWEGO, OR 97526-2037 97036 Page 26 of 27Page 27 of 27