Emily Reyneke Astoria School District Whistleblower Retaliation Motion To Dismiss + Memorandum Regarding Failed Public Defense in Oregon

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'rFlLED
_..._..._............_.
FEB 1 0 2023
IN THE CIRCUIT COUR'l' or THE S'I'A'ru or OREGON
FOR "mu COUNTY or CLATSOP
..-'
Verified Correct Copy of Original'2I10/2023.
Court
.,.
State of Oregon Case No: 23CR0429J§£§QER<Q§§QU It
Plaintiff,
v. CONDITIONAL RELEASE AGREEMENT
Emily Price Reynclte El' THIRD PARTY RELEASE AGREEMENT
Defendant.
Charges: Obtain Attem Obtain e Contents of Communi 'ons' Obtain Attem t o btaiii Use C ntents of
Communications 2301(94264'. ObtainlAttempt to QbtainlUse Contents of Communications; QbtainZAttempt to
ain Us Contents of om unicat'
23QR00:3 29
'
btain A 1n t O 'n U e C n en s of Communication
Monitoring Level: Standard I] Enhanced Cl Intensive

E I will personally appeal" in Clatsop County Circuit Court for all scheduled appearances in this and all other cases.
I will obey all laws, municipal, county, state and federal, and in circumstances in which 'state arid federal law conflict, obey
state law.
>14 I will contact Pretrial Release within two days (503-338-3777) and follow the direction of the Pretrial Release staff
E I will immediatel3' notify the court and pretrial release staff, in writing, of any change in my residence] mailing address/ phone
number and [or email address.
I waive extradition ifl ani arrested outside of Oregon. This document serves as my waiver. Initial:
I will not leave Oregon without written consent of the court or Pretrial Release staff, exceptioxi: Defendant may travel to the
State of Washington for Coast Guard duties.
I will have no direct or indirect contact with the alleged victim(s) or enter onto their premises J
Farmer: effrev Hazen
wr ki 2301(94364: Heidi Winteimute. Jenn

ickenbach: Jeanette Sampson: Grace Laman: MaritzaCasarrubiat
23CR00329
[I I will not possess or have access to firearms, weapons, or ammunition.
[I I will have no contact with co-defendantCs) without permission of court or Pretrial release staff:
I willpromptly contact my attorney and keep in regular contact with them.
Attorney Name: C Lane Borg Phone: 503 462-3774
El I will not use or possess alcohol or controlled substances without a valid prescription from a licensed prescriber.
I] I will not use cannabis without a valid medical registry card. '
I] I will not enter bars, taverns or liquor stores or other places where alcohol is the primai'yr item of sale, exceptioii: __
D I will not drive a motor vehicle without valid license and insurance and will use rm lID if required by the court or DMV..
D I will submit to breath, blood, saliva or urine tests at the request of the Court or Pretrial Release staff and pay all costs.
I] I will submit to a search of my person or vehicle at the request of the Court or Pretrial Release staff, if there is reasonable
suspicion that I have violated a condition of release.
[I I will abide by conditions of probation/parole/post-prison and will report in person immediately upon my release.
I] I will maintain contact with and coo crate with my third-party supervisor.
I] I will be on Electronic Monitoring: GPS; [:1 Sci-am; follow all rules and comply with all requirements of the EM program,
[I I will comply with all FAPA, stalking protective orders, and other protective orders entered against me.
I will report to the jail to be booked and released within 7 days from the date of February 10. 2023.
I] I will not possess animals.
I] I will comply with the reconnnendations of the crisis response team (CRT)
.
D OTHER CONDITIONS:
I HAVE READ AND UNDERSTAND ALL CONDITIONS MARICED ON THIS FORM. I SWEAR I WILL COMPLY
WITH THEM. I ACIG'IOWLEDGE THAT IF I VIOLATE ANY CONDITION(S) OF THIS RELEASE AGREEMENT,
THE AGREEMENT MAY BE REVOKED, A WARRANT MAY BE ISSUED FOR MY ARREST, AND I MAY BE
PROSECUTED FOR CONTEMPT 0F COURT AND/0R FAILURE TO APPEAR. '
//
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l/
l/
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Next Appearance Date: 3/24/23 at 8:30 a.m. in Courtroom 100
Verified Correct Copy of Original 2/10/2023._
[8 Defendant is required to personally appeal' at the next court appearance. Failure to appeal' is subject to prosecution under
ORS 162.195/ 162.205.
Defendant has sworn in court and on the record to follow these
February 10, 2023 conditions.
Date Defendant Signature
110 NW 4th St 013
Warrenton OR 97146 Home: 541-530-1216, Cell: 541-846-8511
Mailing Address Cell Phone Number (Landline if no Cell)
csufiredog@gmail.com 12/18/1982
"
Email Address Date of Birth
n'l ("tram Who I
(tagger tr 7mg 6
Judge / Court Clerk / Deputy Sheriff
IN THE CIRCUIT COURT OF THE STATE OF OREGON
FOR THE COUNTY OF CLATSOP
State of Oregon Case No: 23CR04264 and 23CR00379

Plaintiff,
v. CONDITIONAL RELEASE AGREEMENT
Emily Price Reyneke THIRD PARTY RELEASE AGREEMENT
Defendant.
Charges: Obtain/Attempt to Obtain/Use Contents of Communications; Obtain/Attempt to Obtain/Use Contents of
Communications- 23CR04264; Obtain/Attempt to Obtain/Use Contents of Communications; Obtain/Attempt to
Obtain/Use Contents of Communications; Obtain/Attempt to Obtain/Use Contents of Communications –
23CR00379
Monitoring Level: Standard Enhanced Intensive
I will personally appear in Clatsop County Circuit Court for all scheduled appearances in this and all other cases.
I will obey all laws, municipal, county, state and federal, and in circumstances in which state and federal law conflict, obey
state law.
I will contact Pretrial Release within two days (503-338-3777) and follow the direction of the Pretrial Release staff
I will immediately notify the court and pretrial release staff, in writing, of any change in my residence/mailing address/phone
number and/or email address.
I waive extradition if I am arrested outside of Oregon. This document serves as my waiver. Initial: __________
I will not leave Oregon without written consent of the court or Pretrial Release staff, exception: Defendant may travel to the
State of Washington for Coast Guard duties.
I will have no direct or indirect contact with the alleged victim(s) or enter onto their premises: Susan Farmer; Jeffrey Hazen;
Paul Lewicki – 23CR04264; Heidi Wintermute, Jenna Rickenbach; Jeanette Sampson; Grace Laman; Maritza Casarrubias –
23CR00379
I will not possess or have access to firearms, weapons, or ammunition.
I will have no contact with co-defendant(s) without permission of court or Pretrial release staff:
I will promptly contact my attorney and keep in regular contact with them.
Attorney Name: C Lane Borg Phone: 503 462-3774
I will not use or possess alcohol or controlled substances without a valid prescription from a licensed prescriber.
I will not use cannabis without a valid medical registry card.
I will not enter bars, taverns or liquor stores or other places where alcohol is the primary item of sale, exception: ________
I will not drive a motor vehicle without valid license and insurance and will use an IID if required by the court or DMV.
I will submit to breath, blood, saliva or urine tests at the request of the Court or Pretrial Release staff and pay all costs.
I will submit to a search of my person or vehicle at the request of the Court or Pretrial Release staff, if there is reasonable
suspicion that I have violated a condition of release.
I will abide by conditions of probation/parole/post-prison and will report in person immediately upon my release.
I will maintain contact with and cooperate with my third-party supervisor.
I will be on Electronic Monitoring: GPS; Scram; follow all rules and comply with all requirements of the EM program.
I will comply with all FAPA, stalking protective orders, and other protective orders entered against me.
I will report to the jail to be booked and released within 7 days from the date of February 10. 2023.
I will not possess animals.
I will comply with the recommendations of the crisis response team (CRT)
OTHER CONDITIONS: _
_____________________________________________________________________________________
_____________________________________________________________________________________
I HAVE READ AND UNDERSTAND ALL CONDITIONS MARKED ON THIS FORM. I SWEAR I WILL COMPLY
WITH THEM. I ACKNOWLEDGE THAT IF I VIOLATE ANY CONDITION(S) OF THIS RELEASE AGREEMENT,
THE AGREEMENT MAY BE REVOKED, A WARRANT MAY BE ISSUED FOR MY ARREST, AND I MAY BE
PROSECUTED FOR CONTEMPT OF COURT AND/OR FAILURE TO APPEAR.
//
//
//
//
//
//
//
Next Appearance Date: 3/24/23 at 8:30 a.m. in Courtroom 100
Defendant is required to personally appear at the next court appearance. Failure to appear is subject to prosecution under
ORS 162.195/162.205.
Defendant has sworn in court and on the record to follow these
February 10, 2023 conditions.
Date Defendant Signature
110 NW 4th St D13
Warrenton OR 97146 Home: 541-530-1216, Cell: 541-846-8511
Mailing Address Cell Phone Number (Landline if no Cell)
csufiredog@gmail.com 12/18/1982
Email Address Date of Birth
Judge / Court Clerk / Deputy Sheriff

12/14/2023 12:46 PM
23CR00379
7
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Criminal Department
10
STATE OF OREGON:
11 )
12 No. 23CR00379
Plaintiff
13
EMILY REYNEKE )
14 )
Defendant ) DECLARATION IN SUPPORT OF
15 ) MOTION TO WITHDRAW
)
16 )
)
17
I, Colette M. Cameron, being first duly sworn upon oath, do state:
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1. I have been appointed to represent this defendant.
19
20 2. Ms. Reyneke believes there is a conflict of interest in this matter because I am
21 a member of the consortium that Kris Kaino heads. I have been such a member since
22 October, 2023. Ms. Reyneke is very upset that I did not divulge this information at her
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last hearing. Additionally, Ms. Reyneke believes my request for a 60 day continuance in
24
this matter to prepare for her trial on this case is unwarranted and is causing her
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substantial economic damages. She is requesting a new attorney.
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Page 1 - decuration of colette cameron in support of motion to withdraw

Colette M. Cameron, OSB No. 971694
P.O. Box 131, TillcumLooh:, OR
Phone: (503)502-7554
3 There is a hearing scheduled on this case for February 1, 2024, at 8:30 a.m. |
1
have informed my client will request be removed as her attorney as soon as possible.
| |
2
4. |
request the court allow me to withdraw as defendant's attorney of record
effective immediately.
:
5
5. My client's address is 110 NW 4'" St. #D13, Warrenton, OR.97146.
6 l hereby declare that the above statement is true to the best of my knowledge
7 and belief, and that l understand it is made for use as evidence in court and is subject to
8 penalty for perjury.

9
DATED this _'i%day of '"ifl3¢lfi?&i'f" 023.
10
11
12 CBIette M. Cétfiémn, oss#971694

13 Attorney for Defendant,
Emily Reyneke
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Page 2
DECLARATION OF COLE'I'I'E CAMERON lN SUPPORT OF MOTION TO WITHDRAW
P.O. Box 131, Tfllamook, OR 97141
Phone: (503) 502-7554
2/22/2024 8:47 AM
23CR00379
1 Paul J Charas, OSB 183207

Law Office of Paul J Charas
2 818 Commercial St, suite 104
Astoria, OR 97103
3 T: 503.791.0851
Email: paul@pauljared.com
4
IN THE CIRCUIT COURT FOR STATE OF OREGON
5
6
THE STATE OF OREGON, Case No.: 23CR00379
7
Plaintiff,
8
vs. DECLARATION IN SUPPORT OF MOTION TO
9 WITHDRAW
EMILY REYNEKE,
10
Defendant
11
I, Paul J Charas, being first duly sworn upon oath, do state:
12
13
1. I have been appointed to represent this defendant.
14 2. Upon reviewing initial discovery. I discovered that I have a conflict in this
15 case that requires a mandatory withdrawal pursuant to ORPC 1.7

16
(Conflicts of Interest: Current Clients).
17
3. There is a hearing (status check) scheduled on March 3, 2024, I’ve
18
19
informed my client that I am filing this motion and requesting to be
20 removed as her attorney as soon as possible.
21 4. My client’s address is 110 NW 4th St #D13, Warrenton, OR 97146

22
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DECLARATION IN SUPPORT OF MOTION TO WITHDRAW - 1
1 I hearby declare that the above statement is true to the best of my knowledge
2
and belief, and that I understand it is made for use as evidence in court and is subject to
3
penalty for perjury.
4
5 DATED this 21st day of February 2024 _Paul J Charas____________

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Paul J Charas, OSB # 183207
Attorney for Defendant
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1 CERTIFICATE OF SERVICE
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I, Paul J Charas, Certify that on State v Reyneke 23CR00379 I have delivered a True
4
5 Copy of the Motion to Withdraw to Alex Thomas, DDA by emailing a true copy to
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Alex Thomasathomas@clatsopcounty.gov
7
9 I, Paul J Charas, Certify that on State v Reyneke 23CR00379 I have delivered a True
10
Copy of the Motion to Withdraw to Emily Reyneke, by mailing a true copy to
11
Emily Reyneke
12 110 NW 4th ST. D13
Warrenton, OR 97146
13
14
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DATED this 21st day of February, 2024 Paul J Charas_____________
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20 Attorney for Defendant
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1/9/2024 8:31 AM
23CR00379
7
8
9
Criminal Department
10
STATE OF OREGON:
11 )
12 No. 23CR00379
Plaintiff
13
EMILY REYNEKE )
14 )
Defendant ) SUPPLEMENTAL DECLARATION IN
15 ) SUPPORT OF MOTION TO
) WITHDRAW
16 )
)
17
1. Colette M. Cameron, being first duly sworn upon oath, do state:
18
1. 1 have been appointed to represent this defendant.
19
20 2. Since filing the original declaration in this case, Ms. Reyneke has filed
21 multiple complaints against me with the Oregon State Bar and Oregon Public Defense
22 Services. She continues to assert 1 am engaging in inappropriate conduct. There is a
23
complete and total breakdown in the attorney/client relationship and I cannot work with
24
this client.
25
3. I have informed my client I will request I be removed as her attorney as soon as
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Page 1 — declaration of colette cameron in support of motion to withdraw

P.O. Box 131, Tilkimook, OR 971»41
Phone: (503)502-7554
possible.
123456789
4. i request the court aiiow me to withdraw as defendant's attorney of record
effective immediately.
5. My client's address is 110 NW 4'" St. #D13, Warrenton, OR.97146.
I
hereby declare that the above statement is true to the best of my knowledge
and belief, and that l understand it is made for use as evidence in court and is subject to
penalty for perjury.
DATED this W day of January, 2024.
10
11
"mill/la
caette M.'Cam'§r'o'n, OSB#971694
Attorney for Defendant,
12 Emily Reyneke
13
15 hereby certify that on January 9, 2024 l served a copy of the forgoing Motion,
I ,
Declaration and proposed Order RE: Attorney Vlfithdraw to:

16
17 athomas©clatsopcountv.qov Emily Reyneke

110 NW 4'" St. #D13
18 Warrenton, OR 97146
19
by providing by email a true and correct copy thereof to said individuals as shown
20 above.
21
lama
DATED this wkday of January, 2024.
0
'1 2
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C'olette M. Can'Teron, OSB#971694
24
Attorney for defendant,
25 Emily Reyneke
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Page 2 -
DECLARATION OF COLETI'E CAMERON IN SUPPORT OF MOTION T0 WlTHDRAW'
Colette M. Cameron, OSB No. 97 1694
Bo. Box 1a 1, Tillmook, OR 97141
Phone: (503) 502-7554
PO Box 835 Astoria Oregon 97103
503.325.8555 http://www.courts.oregon.gov/courts/clatsop
November 30, 2023
File Copy
Re: State of Oregon vs Emily Reyneke

Case #: 23CR00379 Offense Misdemeanor
NOTICE OF SCHEDULED COURT HEARING

Hearing date: February 01, 2024 at 3:30 PM
Hearing type: Hearing - Status Check
Hearing location: By video using Webex Meetings
Note: Webex meeting # 2485 748 0442. Email invitation being sent separately.
If you do not receive a Webex invitation, please contact us and provide
your email address.
This hearing will be held by video. The next page of this notice has instructions on how to
appear by video. If you have questions, call us at 503-325-8555.
If you cannot appear by video, please contact us ahead of time and arrange to appear at the
courthouse.
IMPORTANT NOTICE: PLEASE READ

Failure to appear at the time and place noted above may result in a warrant being issued for
your arrest.
Interpreter: If you need an interpreter, you must tell the court at least 4 business days before your appearance date. Go to
www.courts.oregon.gov/ScheduleAnInterpreter to get an interpreter.
Intérprete: Si Ud. necesita un intérprete, debe notificar al tribunal por lo menos 4 días laborales antes de la fecha de su
comparecencia. Para conseguir un intérprete, siga el siguiente enlace: www.courts.oregon.gov/ScheduleAnInterpreter
Hearing Notice – Criminal Status Check-CLT (CD 06/2023) Page 1 of 3

Guide to Video Court Hearings
We use Webex Meetings for our video hearings. You should receive a Webex invitation by email. If you
do not receive an email, please check your spam or junk folder. If you still cannot find the email, contact
us at Docket.Clatsop@ojd.state.or.us or call us at 503-325-8555, option 5.
Important! If you cannot appear by video,

please contact us ahead of time and arrange to Connecting to your hearing:
appear at the courthouse. We have technology
you can use here.  Connect 15 minutes before your scheduled hearing time.
 Click the green button in your Webex invitation email
Get ready for your hearing: that says “Join Meeting” to join
the right application.
 Check your email for an invitation. Click the green
“Join Meeting” button to join the correct site.  You will know you are connected when you can see other
 Make sure your computer or phone can connect to names and cameras in the meeting.
Webex and you understand how it works. Test  If the Webex has not started when you first join, please
your technology at be patient. The court might be finishing another hearing.
www.webex.com/test-meeting.html
 If the Webex has not started by the time your hearing is
 Make sure you have good Wi-Fi or wired internet scheduled, please call us to make sure you are in the
connection. Cellular internet is generally not right place.
strong enough for a video hearing.
 Charge your computer or phone before your
hearing. Audio tips:
 Sit somewhere quiet and without distractions.  Press “Mute” or “Unmute” to control your microphone.
 Wear clothing that is appropriate for court. Do not

wear hats, sunglasses, or revealing clothing.
 Keep your microphone muted unless the court or your
 If you do not have a lawyer, contact us for lawyer asks you to speak.
instructions on submitting exhibits or having
witnesses appear.  Use headphones if you can.
 Speak slowly and clearly into your microphone.
What to expect at your hearing:  Use language appropriate for court.
 The judge or court staff will make sure you can
hear them and they can hear you. Video tips:
 Although you are not physically in a courtroom,  Press “Start video” to turn on your camera.
video court is still court. Please act like you would
in a courtroom.
 You may see people or names you do not
recognize. Your hearing may be in a group with  Keep your camera on and pointed at your face.
several other hearings. Please be patient.  Keep your camera still. Do not move it around during
your hearing.
Contact us:
For immediate assistance, call us at 503-325-8555 and press option 0 (zero).
Si tiene preguntas, llame al 503-325-8555 y elija opción 0 (cero).
To request a Webex invitation, send an email with your name and case number to Docket.Clatsop@ojd.state.or.us or call us at
503-325-8555, option 5.

November 30, 2023
Dear Colette M Cameron,
This case is set for a Hearing – Status Check on 02/01/2024.
Please be prepared to inform the judge whether the case is resolved or will proceed to trial.
Dates for motions, trial or change of plea will be set at this hearing. No other matters will be
addressed.
If you notify the court of your election in writing prior to the hearing you will not need to appear.
Attached is a form for your use.
Thank you,
Clatsop County Circuit Court
__________________________________________________________________
State of Oregon
vs
Emily Reyneke Case #: 23CR00379
REQUEST
Dear Clatsop Circuit Court Calendaring Department,
Please cancel the Hearing – Status Check on 02/01/2024 and set:
 Call and Trial

 Change of Plea
 Plea and Sentencing
Notes about this request: ________________________________________________
__________________________________________________________________
 I have served this request upon the Clatsop County District Attorney’s office.
Attorney Signature: ______________________________ Date: _____________

10/27/2023 2:13 PM
23CR00379
I
., IN THE CIRCUIT COURT OF THE STATE OF ORf,CON

3
STATE OF OREGON,
4
Plaintiff, SECOND AMENDED INFORMATION
5 vs. Court No. 23CR00379
6 EMILY PRICE REYNEKE DA No. 0066080

Defendant
7
The defendant is accused by Ron Brown, District Attomey for the County ofClatsop, by this Amended
8
lnformation, ofthe crime(s) ol
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Count I : INTERCEPTION OF COMMUNICATIONS (Class A Misdemeanor; ORS 165.540(a)) FPC#
l0
Count 2: INTERCEPTION OF COMMUNICATIONS (Class A Misdemeanor; ORS 165.540(e)) FPC#
ll committed as follows;
l2 UNT I
The defendant, on or about October 12, 2022, in Clatsop County, Oregon, did unlawfully and knowingly obtain the
whole or a part oftelecommunication by means ofa device, contrivance. machine or apparatus, to-wit: a cell phone, the
l3
defendant not being a participant or having consent ofany participant to the said telecommunication. ;
14 COUNT 2
The defendant, on or about October 13, 2022. in Clatsop County, Oregon, did unlawfully and knowingly use, attempt to
l5 use or divulge to others, to wit: the general public a telecommunication obtained by means ofa device, contrivance,
machine or apparatus. to-wit: a cell phone. the defendant not being a participant or having consent ofany participant to
the said telecommunication:
l6
The counts alleged in this charging instrument are based on the same act or transaction and/or ofsame or similar
t7 character.
l8
t9
20
21
)',
23
21
I INFORMATION
Clatsop Coun! Dislticl Allo e!

719 Cotuterciol Street
P.O. Box 149
Astotia, Orcgoh 9710J (503) 325-E581
I said act ofdefendant being contrary to the Statutes in such cases made and provided, and against the peace and dignity of
the State oforegon. The State declares its intention to treat any misdemeanor named herein as a crime. Bythe below
^,
signature, the Deputy District Attomey certifies that under the penalties described in ORS 133.992, there are sufficient
grounds to believe and the Deputy District Attomey does believe that the defendanl named in the information committed
3
the offense(s) specified in the information.
4
DATED: October 27. 2023
5
RON BROWN
6 DISTRICT ATTORNEY FOR CLATSOP COUNTY, OREGON
7 BY
Alexander A Thomas, OSB 222324
8 Deputy District Attorney
athomas@clatsopcounty. gov
9
l0 Trial Attorney: Alexander A Thomas, OSB No.222324

Anesting Agency Case #: ATP 420223288
ll DA No.: 0066080
IDENTIFIERS: F,'W Ht: 5'07 wt: 223 Hair: BRO E1'es: HAZ
t2 DOB: l2118/1982 Control #
t3
l4
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l6
l7
l8
l9
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2t
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23
21
2 INFORMATION
Clatsop Counlf Difiticl Altomer"

749 Conunercial Strcet
P.O. Box 149
Asrotio, Otegon 97103 (503) 325-E5El
CERTIFICATE _ TRUE COPY _ WELL FOUNDED In* LAW
CERTIFICATE OF Sf,RYICE
I hereby certiff that the foregoing copy of SECOND AMENDED INFORMATION is a
copy ofthe original. That the said pleading in my opinion is well founded in law. I hereby
certilj/ that a foregoing copy was served on C. Lane Borg, attorney of record for the defendant, on
October 27, 2023 by method(s) as indicated below, pursuant to ORCP 9:
a Odyssey File & Serve to the email address provided by said attorney;
n USPS to the address provided by said attomey;
tr Inter-office mailbox designated at the Clatsop County District Attorney's Office
Dated this 27th day ofOctober,2023,
'l
/s/Alexander A homas
Of Attorneys for the State of Oregon
District Attomey for Clatsop County

P. O. Box 149
Astoria, OR 97103
(503) 325-8581 Main Line
(503) 3 25-93 05 Fax
daoffi ce@clatsopcounty. gov
7/13/2023 10:36 AM
23CR00379
I
IN THE CIRCUIT COURT OF T}IE STATE OF OREGON
7
FOR THE COI,JNTY OF CLATSOP

3
s |'ATE OF ORECON.
I Plaintifl'- AMENDED INFORMATION
\:5 Court No. 23CR00379
E,VItLY PRICT] RI]YNEKE DA No. 0066080

6 Def'endant
The defcndant is accused by Ron Brown, District Attorney for the County ofClatsop, by this Amended
7
Information. ofthe crime(s) ofl
8 Count l: INTERCEPTION OF COMMUNICATIONS (Class A Misdemeanor; ORS 165.540(a)) PPC#
9 Count 2: IN'|ERCEPTION OF COMMUNICATTONS (Class A Misdemeanor: ORS 165.540(e)) FPC#
committed as follows:
10 COT]NT 1
The del-endant, on or about October 12, 2022, in Clatsop County, Oregon, did unlarvfully and knowingly obtain the
ll whole or a part oftelecommunication by means ofa device, contrivance. machine or appamtus. to-wit: a cell phone, the
def'endant not being a parlicipant or having consent oIany participant to the said telecommunication. ;
COL]NT 2
L2 'l
he defendant, on or about October 13, 2022, in Clatsop County, Oregon, did unlawfully and knowingly use^ attempt to
use or divulge to others, to rvit: the general public, a telecommunication obtained by means ofa device. contrivance.
l3 machinc or apparatus. to-wit: a cell phone. the defendant not being a padicipant or having consent ofany participant to
the said telecommunication:
14
said act ofdefendant being contrary to the Statutes in such cases made and provided, and against the peace and dignity of
t5 the State oforegon. The State declares its irtention to aeat any misdemeanor named herein as a crime. By the below
si€nature. the Depury Dist ct Attomey certilles that under the penalties described in ORS 133.992, there are sufficient
l6
grounds to believe and the Deput-y District Attorney does believe that the det'endant named in the infbrmation committed
l7 the off'ense(s) specified in the infonnation.
ll{ DATED: J uly 12.2023

l
l9 RON BROWN
DISTRICT ATTORNEY FOR CLATSOP COUNTY. OREGON
lli BY
--iloZlutt
Alexander A Thomas- OSB 22212;l
Deputy Dist ct Attorney
l
I
athorrar 1A
z2
'l rial Attomey: Alexander A Thomas, OSB No.222124
Arresting Agency Case #: ATP A20223288
23 DA No.: 0066080
21 IIIF-NTIFIERS: F/W t{t: 5'07 wt: 223 Hair: BRO Eves: HAZ
DOB: 12,/18/1982 Control #:
IINFORMATION
Cldsop Counq Di\ttict Attotnet
749 ('om,iercial Strcet
P.O. Box 119
/1ttoria, Oregon 97103 (503) 325-8581
CERTIFICATE _ TRUE COPY _ WELL FOUNDED IN LAW
CERTIFICATE OF SERVICE
I hereby certi$, that the foregoing copy ofAmended Information is a copy ofthe original.
That the said pleading in my opinion is well founded in law. I hereby certiry that a foregoing
copy was served on C. Lane Borg, aftorney of record for the defendant, on July 13, 2023 by
method(s) as indicated below, pursuant to ORCP 9:
l\] Odyssey File & Serve to the email address provided by said attorney;
! USPS to the address provided by said attomey;
! Inter-office mailbox designated at the Clatsop County District Attorney's Office.
Dated this l3th day ofJuly.2023.
/s/ Alex Thomas

Of Attomeys for the Stale of Oregon

P. O. Box 149
Astoria, OR 97103
(503) 325-8581 Main Line
(503 ) 325-9305 Fax
1 l;
'1'

Verified Correct Copy of Original 1/3/2023.
2 FOR THE COUNTY OF CLATSOP

2823 JA?%_ BPH 3: 33
3 STATE OF OREGON,
TRIAL COURT MR'Xiiiiémfiiflri
Plaintiffi INFORMATION
4
VS. CourtNoZECK0057q
{WWW "£251.."
5 EMILY REYNEKE DA No. 0066080

Defendant.
6
The defendant is accused by Ron Brown, District Attorney for the County of Clatsop, by this Information,
of the crime(s) of:
7
Count 1: INTERCEPTION OF COMMUNICATIONS (Class A Misdemeanor; ORS 165.540) FPC#:

9
10
committed as follows;
11 COUNT 1
The defendant, on or about October 13, 2022, in Clatsop County, Oregon, did unlawfully and knowingly obtain the
12 whole or a part of a conversation fiom a person, to-wit: the Astoria School Board, knowing or having good reason to
know that such conversation was initially obtained by leaving a phone recorder in the room where the executive session
was going on;
13
COUNT 2
14 The defendant, on or about October 13, 2022, in Clatsop County, Oregon, did unlawfully and knowingly obtain the
whole or a part of a conversation by means of a device, contrivance, machine or apparatus, towit. a phone recorder, all
15 participants in the conversation not being specifically informed that their conversation was being obtained;
16 COUNT 3
The defendant, on or about October 13, 2022, in Clatsop County, Oregon, did unlawfully and knowingly use, attempt to
use or divulge to others, toiwit: Facebook, a conversation obtained by recording an executive session of the Astoria
17 School Board;
18
19 said act of defendant being contrary to the Statutes in such cases made and provided, and against the peace and dignity of
the State of Oregon. The State declares its intention to treat any misdemeanor named herein as a crime. By the below
signature, the District Attorney certifies that under the penalties described in ORS 133.992,
there are sufiicient grounds
20
to believe and the District Attorney does believe that the defendant named in the information committed the ofiense(s)
21 specified in the information.
DATED: December 30, 2022

22
RON BROWN
23 DISTRI T AT ORNE RNEY OR CLATSOP COUNTY, OREGON
24
BYTNFORIéATIONW
1
Clatsop County District Attorney

749 Commercial Street
P. 0. Box 149
Astoria, Oregon 97103 (503) 325-8581
1 Ron Brown, OSB 791726
District Attorney
Verified Correct Copy of Original 1I3/2023._
rbrown@clatsopcounty. gov
2
Case proceeding to: D Grand Jury D Preliminary Hearing
4 Trial Attorney: Ron Brown, OSB No. 791726

Arresting Agency Case #z AT_P A20223288
DA No.: 0066080
u:
IDENTIFIERS: F/W Ht: ' Wt: Hair: Eyes:

6 DOB: 12/18/1982 Control #:
10
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23
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2
INFORMATION
Clatsap County District Attorney

P. 0. Box I49
Astoria, Oregon 97103 (503) 325-8581
2/1/2024 12:42 PM
23CR00379
Emily Reyneke
110 NW 4 th Street SPC D13
Warrenton, Oregon 97146
(541) 846-8511
csufiredog@gmail.com
Re: 23CR00379
Dear Clatsop County Circuit Court,
I am writing a letter into this case because Clatsop County Circuit Court Staff, in
particular Dawn Benthin and Cindy Whitten, have been engaging in deliberate
misconduct that has prevented me from getting notices of hearings et al with an intended
purpose of getting me put in jail. Cindy can’t even remain professional and repeatedly
laughed at me this morning. I did not receive a notice for this morning’s hearing nor for
the last hearing in any form.. Had I received notice, I would have been at this morning’s
hearing. I had previously wrote a letter to the Trial Court Administrator Julie Vredeveld to
inform her about some of the issues going on, and Cindy Whitten knowingly and
intentionally intercepted the letter, made assumptions without fact, only partially reading
the letter, then knowingly and intentionally sent the letter back to me. I have informed the
court staff repeatedly that Dawn Benthin should not be having anything to do with this
case including scheduling. The reason for this is that she has a conflict of interest, and is
one of the individuals who are engaging in or who have engaged in cyberbullying related
to this case.
I never received any notice, Webex email alert, or Google Calendar alert (which is linked
to Webex). The only way I found out was when I picked up my phone about 10:30a.m.
and there was a voicemail from Paula. I did not get Paula’s phone call when she called
because I am recovering from a cold and had briefly fallen back asleep. When I attempted
Emily Reyneke
(541) 846-8511
to return Paula’s call and inform her that I did not get notice of the hearing, the court
clerk acted like an immature individual who lacked ability to process basic information.
Then Cindy Whitten continued the immature behavior with the laughing and refusing to
figure out why I hadn’t been sent notice of the hearing.
Again, I was not sent notice of the hearing in any form. Not a paper notice via mail, not
by email, not even a WebEx invite or calendar reminder (that’s linked to Webex). Please
rescind the warrant and reset the hearing; and direct court staff i.e. Elisa or April to call
me to confirm that I received the notice and know about the hearing date. Please also
order that Dawn Benthin or Cindy Whitten have absolutely nothing further with this case;
and that any issues that may arise that would require a supervisor, that the Trial Court
Administrator Julie Vredeveld be the individual to communicate with me.
Also of note, I had been working on preparing a document to inform the court that
Colette Cameron had engaged in perjury when she filed the motion to withdraw. That will
be forthcoming. I do not have a printer, so please accept this letter without a hand written
signature.
Additionally, when Cindy Whitten was being unprofessional and engaging in misconduct
she mentioned a pretrial release agreement that was adjusted. I never received a new
pretrial release agreement when Clatsop County District Attorney Alex Thomas moved
for the case to be dismissed and refiled. Nor was a new pre trial release agreement ever
Emily Reyneke
(541) 846-8511
discussed in any hearing after Alex Thomas refiled the case. The court record (audio)
would reflect that.
Respectfully submitted,
Emily Reyneke
Cc: Alex Thomas via email athomas@co.clatsop.or.us, Clatsop County DA’s office via
email daoffice@clatsopcounty.gov
3/7/2024 3:11 PM
23CR00379
1 IN THE CIRCUIT COURT OF THE STATE OF OREGON
2 COUNTY OF CLATSOP
3 STATE OF OREGON, Case No.: Number

23CR00379
4 Plaintiff,
5 vs. MEMORANDUM
6 EMILY REYNEKE,
7 Defendant
9 Clatsop County Circuit Court,
10
11 This memorandum is being written in response to attorney Paul Charas’ Motion to
12 Withdraw and in support of Defendant’s Motion to Dismiss.
13
14 On February 21, 2024, Paul Charas filed a Motion to Withdraw and a Declaration In
15 Support of Motion to Withdraw. Mr. Charas included a declaration under penalty of
16 perjury that he had served a copy of the Motion to Withdraw and the Declaration upon
17 the Defendant. When in fact, he had not. I did not receive a copy of the motion and
18 declaration until March 7, 2024 when I had to specifically ask for it.
19
20 During a phone meeting with Mr. Charas, Mr. Charas admitted that at the time of the
21 purported incident, he was an employee of the Clatsop County District Attorney’s Office.
22 MEMORANDUM - 1
23
24
l And, that he had conversations with Mr. Ron Brown, Clatsop County District Attorney
2 regarding the case. Mr. Charas then also disclosed/admitted to knowing several of the
"witnesses" in the matter, but refused to identify which witnesses. And as a result he has
4
ZI
a conflict of interest.
6 Mr. Charas would go on to repeatedly make statements that he wants to "keep his
7 license" and that he "likes his license". Within the context of the conversation, facts
8 known, his tone, the fact that Mr. Charas had been assigned to Defendant, etc. it is
9 believed that Mr. Charas may have been placed under fear of retaliation by Ron Brown or
10 the "witnesses" if the outcome of the case was anything other than a conviction. And at
ll minimum he was concerned about it.
12
13 Even though Mr. Charas deliberately attempted to withhold information, the information
l4 was still uncovered. Mr. Charas resides at 3496 Harrison Avenue, Astoria, Oregon
15 97103. Judge Kirk and Heidi Wintermute reside at

16
l7
_ This means that Paul Charas and Kirk and Heidi Wintermute are
neighbors and personal friends of Paul Charas. Paul Charas is also one of the individuals
18 who gave misinformation to Heidi Wintermute and was further disseminated by Heidi
19 Wintermute which led to the meritless case being filed to begin with.
20
21 Additionally, during his tenure at Clatsop County District Attorney's Office, he was
22
MEMORANDUM -2
1 leaking information to Kirk and Heidi Wintermute which was further disseminated and
2 has been continually used to harass, slander, intimidate the Defendant pre-trial including
3 deliberately repeatedly seeking the termination of the Defendant’s employment from
4 private employers each time it’s discovered that the Defendant has gained a new job.
5 Additionally, one of the state’s witnesses, Janelle Wagner, who is an employee of the
6 Astoria School District, has as recently as Saturday, March 2, 2024 slandered the
7 Defendant and deliberately attempted to deter community members from doing business
8 with the Defendant on social media.
10 The case is without any merit. There are massive credibility issues with every one of the
11 state’s witnesses. The state has failed to preserve physical evidence. There ’s been
12 misconduct by Alex Thomas and Ron Brown on the case which in and of itself is grounds
13 for dismissal. And ultimately, the court has been entertaining a meritless case whose only
14 real purpose is to thwart accountability of the individuals through legal/proper channels
15 who caused the case to be filed in the first place, Heidi Wintermute et al and to attempt to
16 silence a United States citizen from exercising constitutional rights. So the only thing that
17 the court is currently doing besides wasting massive amounts of it’s own time, is further
18 violating the Defendant’s legal rights which includes renumeration for the civil torts
19 committed by Heidi Wintermute, Maritza Casarrubias, Janette Sampson, Jenna
20 Rickenbach, and Grace Laman. And that’s not the purpose of this court. The court at this
21 time must dismiss this case with prejudice. Whether it holds individuals including Paul
22 MEMORANDUM - 3
23
24
1 Charas et al in contempt for misusing the court and making false statements under
2 penalty of perjury, that is up for the court to investigate and decide.
4 Please accept the electronic filing of this memorandum as the signature of this
5 Memorandum. I do not have a printer and am not in a position to be able to print and send
6 the document via USPS.
8 Submitted this 7 th day of March, 2024
9 Emily Reyneke
10 110 NW 4 th Street SPC D13
11 Warrenton, Oregon 97146
12 (541) 846-8511
13 csufiredog@gmail.com
14
16 I certify that on March 7, 2024 that I emailed a copy of Defendant’s Memorandum to
17 Alex Thomas, OSB# 222324 at athomas@co.clatsop.or.us as well as
18 daoffice@clatsopcounty.gov.
19
20 I certify that on March 7, 2024 that I emailed a copy of Defendant’s Memorandum to
21 Paul Charas, OSB#183207 at paul@pauljared.com.
22 MEMORANDUM - 4
23
24
1/31/2023 3:25 PM
23CR00379
I IN THE CIRCUIT COURT OF THE STATE OF OREGON
FOR THE COLINTY OF CLATSOP

2
STATE OF OREGON, )
., ) MEMORANDUM IN SUPPORT OF
Plaintiff, ) MOTION TO CONSOLIDATE
4 )
)
) Court Nos. 23CR00379
5 EMILY PRICE REYNEKE, ) 23CR04264
)
6 Defendant )
7 In these two cases, defendant is alleged to have committed crimes involving Unlawful
8 Interception of Communications involving the Astoria School as well as Sunset Empire
9 Transportation. ORS 132.560(2) allows the court to consolidate two or more sets of charges
l0 where the charges are the same or similar. Both charging documents against defendant allege
il Unlawful Interception of Communications and only differ as to the number of counts alleged and
12 therefore qualify. See St. v. Tidewell, 259 Or App 152 (2013) where two DUII charges 7
l3 months apart were ruled to be properly joined. As the caselaw says, as long as the cases are of
t4 the same or similar character, the state's interest in economy outweighs any alleged prejudice.
15 St. v. Mever, 109 OrApp 598 (1992). Meyer is based upon federal caselaw which upheld an
l6 analogous federal statute of the same kind. See US v. Wemer , 620 F2d 922,926 (2nd Circuit,
l7 1980) which cites prior federal caselaw. Edwards v. Squier, 178 F2d 758,759 (1949). So long
l8 as the evidence is separate and distinct, the jury may be instructed that they are to consider each
l9 count and case separately. See also St. v. Jones, 184 OrApp 57 (2002) which upheld defendant's
20 convictions for multiple counts of sexual abuse committed against three victims.
2t The caselaw further points out ORS 132.560(3) which allows either side to move to sever
22 if it becomes an issue of substantial prejudice to that pa(y. Perhaps the best example ofthe
23 Oregon joinder/severance statute is St. v. Barone, 329 OR 210, 217 (1999), where defendant was
21 charged originally with the murder of four different women in separate criminal episodes. The
Page I - MEMORANDUM IN SUPPORT OF MOTION TO CONSOLIDATE
Claaop Counly Distticl Attoney

719 Cohmercial Slreet
Attoria, Orcgon 97103 (503) 325-ESEI
I State actually moved to sever one of the murders and then they tried the other three, obtaining
2 guilty verdicts involving all victims. Consolidation was upheld on appeal.
3 At this juncture, when defendant has perhaps an incomplete view ofthe discovery and its
4 implications, the State asks that defendant's objection to consolidation be ovemrled with leave to
5 renew down the road as a motion to sever.
6 Dated this 31st day of January, 2023.
7 1
8 RO osB # 791726
Distric Attornev
9
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II
t2
l3
t4
l5
t6
t7
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2t
7)
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Page 2 - MEMORANDUM lN SUPPORT OF MOTION TO CONSOLIDATE
Cl.tlsop Counr! Distticl Altornql

749 Contmercial Slrcet
Astorio, Otegon 9710J (503) 325-8581
8/10/2023 4:40 PM
23CR00379
1A
CLATSOP COUNTY DISTRICT ATTORNEY'S OFFICE
Post Office Box I49
Astoria, Oregon 97103
oPc (503) 325-8581 Fax: (503) 325-9305
MEMORANDUM
TO: Clatsop County Circuit Court
Lane Borg
FROM: Alicia Turigliano, Trial Assistant

amturigl iano@clatsopcounty.gov
RE State ot Oregon vs. Emily Price Reyneke

DA Case No. 0066080: Coun Case No.2lCR00379
DATE: August 10, 2023
The District Attomey's office has received Mr. Borg's Motion to Dismiss for the above-referenced
case
Deputy District Attomey, Alex Thomas objects to a dismissal
CERTIFICATE _ TRUE COPY - WELL FOUNDED IN LAW
CERTIFI('ATE OF SERVICE
I hereby certifl that the foregoing copy of Memorandum is a copy ofthe original. That
the said pleading in my opinion is well founded in law. I hereby certiry that a foregoing copy was
served on C. Lane Borg, attomey ofrecord for the defendant, on August 10, 2023 by method(s)
as indicated below, pursuant to ORCP 9:
Odyssey File & Serve to the email address provided by said attorney;
! USPS to the address provided by said attorney;
n Inter-office mailbox designated at the Clatsop County District Attomey's Of-fice.
Dated this lOth day ofAugust,2023.
/s/A[ex)A. tfromas
Dishict Attomey for Clatsop County

P. O. Box 149
Astoria, OR 97103
(503) 325-8581 Main Line
(s03) 32s-930s Fax
9/26/2023 10:44 AM
23CR00379
1

3
STATE OF OREGON.
Plainrifl STATE'S BRIEF IN OPPOSITION TO
4
DEFENDANT'S MOTION TO
VS DISMISS
5
EMILY PRICE REYNEKE Coun No. 23CR00379
6 Defendant
DA No. 0066080
8 I}ACKCROUND
9 The State alleges on October 12, 2023, defendant Emily Reyneke attended a public meeting ofthe Astoria
School Board. The meeting was between the board members who were attending in person, and the board's attomey
l0
Callen Sterling who was attending via a telephone call being broadcast on a speaker. At one point in the meeting, the
ll
board entered "executive session" and asked members ofthe public (including defendant) to leave. The State alleges
l2 defendant left her cell phone in the meeting room with the recorder activated in order to capture the conversations
l3 between the board and Ms. Sterling. The State alleges no participant in the telephonic conversation was aware ofor
l4 consented to the recording. Lastly, the State alleges defendant posted the telephonic conversation in which she was
not a participant on Facebook. The State filed an information which contains one count of violating ORS 165.540(a)
l5
and one count of violating ORS 165.540(e). The defendant filed a motion to dismiss which is the subject ofthis
t6
brief.
l7 DEFENDANT'S MOTION TO DISMISS
Itt On August 8,2023, defendant filed a motion to dismiss. The motion's sole basis is the recent 9th circuit
l9 ruling Project Veritas v. Michael Schmidt,'72 F .4th 1043 (9s cir. 2023). Defendant claims the case strikes down the
entirety ofORS 165.540. The Sate anticipates the argument will be based on instances in the opinion in which the
20
court refers to subsections 165.540(l)(c), 5(a), and 5(b) as the "statute." The State disagrees.
2l
22
23
2t
I STATE'S BRIEF IN OPPOSITTON TO DEFENDANT'S MOTION TO DISMISS
Clotso| Counij Dislricl Afto e!

749 Conmercial Slrcet
P.O. Box 149
Astorio, Otegon 97103 (503) -]25-E581
I
I LAW
ORS 165.540 has several subsections. Subsecrion ( l) enumerates five different causes ofaction (a-e)
2
related to different forms ofobtaining the contents ofa communication. Each is distinct and has differing elements.
3
Subsection (2)-(7) enumerate several exceptions in which the conduct described in section ( I ) would not constitute a
4
crime. The exceptions in subsection (5) apply only to ( l)(c).
5 In Proiect Veritas v. Mi chael Schmid the petitioner, an investigative non-profit Project Veritas, sued
6 I Oregon Attomey Ceneral. Elen Rosenblum, and the District Attorney of Multnomah County, Michael Schmidt
I
lseekinganenjoinderagainst"enforcingsectionl65.540(l)(c)."72F.4th1043, 1052-53 (9'h cir.2023). The

7
I
I petitioner claimed the subsection "favored recording some subjects, but disfavored others, the differential treatment
8 I
I rendered section 165.540(lXc) and its exceptions unconstitutional." Id. l,J1052.

9 I
I The coun went on to hold section 165.540(l)(c) when paired with the exceptions in 165.540(5)(a) and
t0 | I
151b1was a content-based restriction on speech. 1l at 1057. As such, the court applied a strict scrutiny evaluation
I
il I and found Oregon did not have a compelling interest and the subsection was not narrowly tailored to address the
I
l2 I
State's interests. ld. at 1060-62. Lastly, the court addressed the question ofthe exceptions' severability from
165.540( l1c). The court found severing the exceptions would not rescue (I Xc) because the court found even absent
l3 I
the exceptions. ( I Xc ) as a standalone provision does not survive intermediate constitutional scrutiny. 1d at 1065-66.
l1 I
I The court so found based on the fact that ( I Xc) does not offer ahemative channels for the creation of audio-visual
t5 I I
recordings because the coun reasoned the notification requirement "would effectively destroy the intended content
I
l6 loftherecording."/d.Assuchthecourtfoundthat"sectionl65.540(1)(c)asawhole...isaconlent-basedspeech
I
lrestrictionthatcannotsurvivestrictscrutiny..."andthat"[t]hestatuteisalsonotavalidtime,place,ormanner
17
I
restriction because it does not leave open ample altemative channels for communication." ld. at 1068.
l8 I
l9
APPLICATION
211 Defendant has been charged with two counts: one count for violating ORS 165.540(lXa); and one count for
21 violating ORS 165.540( l)(e).
,, Without conceding whether or not Project Veritas v. Michael Schmidt is actually binding on Oregon State
courts in regards to their treatment of ORS 165.540( I )(c). one thing is clear: Veritas has nothing to say regarding
23
165.540(l)(a) and (e) the subsections at issue in this case. Perhaps the strongest argument in favor ofthis reading
21
is the plain meaning of the court's writing. The opinion clearly defines the scope of its concem as I 65.540( I Xc),
2 _ STATE'S BRIEF IN OPPOSITION TO DEFENDANT'S MOTION TO DISMISS
clalsop courrl! Dislticl Attonet)

719 Contmercitl Streel
P,O. Box 149
Astotia, orugoh 9710.1 (50-]) 325-8581
I (5)(a), and (5)(b). 72F.4th 1043,1052-53 (9'r'cir. 2023). The coun consistently refers to those sections exclusively.
) The State anticipates the defendant will attempt to highlight the occasional instance in which the coun substitutes
the term "statute" as shorthand for subsections l(c), (5Xa), and (5Xb) in an attempt to argue Project Veritas strikes
3
down the entirety of 165.540 as unconstitutional. Beyond being inconsistent with the vast majority ofthe language
4
ofthe opinion, such an expansive reading would be nonsensical for a number ofother reasons.
5 From a procedural perspective, the petitioner's suit did not challenge subsections l(a) and l(e). In its
6 original action, petitioner challenged 165.540l(c). l(d), and l(e). /d at footnote 6. However, the parties later agreed
to dismiss the claims against l(d) and l(e) with prejudice. /d Therefore, the only subsection which was even before
7
the court was l(c). Accordingly, the court made no ruling as to l(a) and l(e) - the subsections al question in this
8
case
9
Further, the court's strict and intermediate scrutiny analysis are base on the particular language and
10 elements ofsubsection (l)(c); which are distinct from the elements of l(a) and l(e).
ll For example, (l)(c) only applies unless not all participants "are specifically informed that their
conversation is being obtained," while (l )(a) is only triggered ifnone ofthe panicipants to the telephonic
t2
conversation consent to the recording, whereas ( I )(e) has no notice or consent elements at all. Yet the court's
13
analysis finding that I (c) does not offer sufficient alternative avenues to survive stand-alone intermediate scrutiny
11
hinges on the fact that a// participants must be informed to avoid triggering ( I )(c) - an element not at issue in (I Xa)
l5 or l(e). Id at 1065-66. The rest ofthe court's constitutional analysis is similarly tied to the panicular and distinct
t6 elements of(l )(c). It would be nonsensical to apply a constitutional analysis ofa cause ofaction based on particular
elements to other causes ofaction with wholly different elements.

17
Additionally, part ofthe court's analysis is based upon disparate treatment for different types ofspeech
t8
which is created under the exceptions in 165.540(5)(a) and (5Xb). However, the exceptions in I65.540(5) apply only
19
to (I Xc). Again, the court's logic does not implicate (I Xa) and (| Xe).
20 Defendant points to a handful of instances when the court substitutes the term "statute" as shorthand for
21 (I )(c), (5)(a), and (5)(b). However, this is wishful reading which ignores the vast majority of the opinion. Take the
t1 court at its words, the opinion is a narrowly targeted scalpel not a sledgehammer.
23
24
3 . STATE'S BRIEF IN OPPOSITION TO DEFENDANT'S I\4O'T'ION TO DISMISS
clatsol, coanl! Dislticl Altorne!

749 Commucial Strcel
P.O- Rot 149
Astotiu, Orcgo 97l0l (50.1) -125-8581
CERTIFICATE _ TRUE COPY _ WELL FOt]NDf,D IN LAW
I hereby certif, that the foregoing copy of State's Brief In Opposition To Defendant's
Motion To Dismiss is a copy of the original. That the said pleading in my opinion is well
founded in law. I hereby certii/ that a foregoing copy was served on C. Lane Borg, attomey of
record for the defendant, on September 26, 2023 by method(s) as indicated below, pursuant to
ORCP 9:
x Odyssey File & Serve to the email address provided by said attomey;
n USPS to the address provided by said attorney;
tr Inter-office mailbox designated at the Clatsop County District Attomey's Office
Dated this 26th day of September,2023
Thomas

P. O. Box 149
Astoria, OR 97103
(503 ) 325-8581 Main Line
(503) 325-9305 Fax
2/22/2024 8:45 AM
23CR00379
1 Paul J Charas, OSB 183207

Law Office of Paul J Charas
Astoria, OR 97103
3 T: 503.791.0851
4
5
6
7
Plaintiff,
8
vs. MOTION TO WITHDRAW
9
EMILY REYNEKE,
10
Defendant
11
COMES NOW Paul J Charas, counsel for the defendant, Emily Reyneke, and
12
13
MOVES the Court for an Order Allowing Withdrawal of Counsel. This motion is based on
14 RPC 1.7 current client conflicts and is in the opinion of counsel mandatory.
15
DATED this 21st day of February, 2024 _Paul J Charas____________
16
17
19 POINTS & AUTHORITIES

RPC 1.7
20
21
22
23
24
25
26
27
28
MOTION TO WITHDRAW - 1
2
3
I, Paul J Charas, Certify that on State v Reyneke 23CR00379 I have delivered a True
4
5 Copy of the Motion to Withdraw to Alex Thomas, DDA by emailing a true copy to
6
Alex Thomasathomas@clatsopcounty.gov
7
9 I, Paul J Charas, Certify that on State v Reyneke 23CR00379 I have delivered a True
10
Copy of the Motion to Withdraw to Emily Reyneke, by mailing a true copy to
11
Emily Reyneke
12 110 NW 4th ST. D13
Warrenton, OR 97146
13
14
15
16
17
DATED this 21st day of February, 2024 Paul J Charas_____________
18
19
21
22
23
24
25
26
27
28
MOTION TO WITHDRAW - 2
12/14/2023 12:46 PM
23CR00379
7
8
9
Criminal Department
10
STATE OF OREGON;
11 )
Plaintiff )
12 ) No. 23CR00379
EMILY REYNEKE,
13
Defendant. )
14 ) MOTION TO WITHDRAW
)
15 )
)
16
17 COMES NOW, Colette M. Cameron, attorney of record for Emily Reyneke, in
18 the above-entitled action, and hereby moves this Court for an Order allowing withdrawal of
19 Colette M. Cameron from any further representation of her herein, upon the grounds and
20 for the reasons set forth in the Declaration of Colette Cameron, filed herewith.
21
DATED this day of December, 2023
22
23
Colette M. Cameron, OSB#971694
24 Attorney for defendant, Emily Reyneke
25 ////
26 ////
Page 1 - motion to withdraw

P.O. Boji 131, Tillcunook, OR 971'il
Phone: (503) 502-7554
1
2
3 hereby certify that on December 14, 2023 l served a copy of the forgoing
|
,
Motion, Declaration and proposed Order RE: Attorney Withdraw to:

4
athomas@c|atsopcounty.qov Emily Reyneke
5 110 NW4th St. #D13
Warrenton, OR 97146
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by providing by email a true and correct copy thereof to said individuals as shown
8 above.
9 DATED this m' day of December 2023.

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11 nquWQMOSB#971694
glette M. Cameron,
12 Attorney for defendant,
Emily Reyneke
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Page 2 -
MOTION To wn'HoRAw
P.O. Box 131, 'I'illamook, OR 97141
Phone: (503) 502-7554
1/27/2023 3:20 PM
23CR00379
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) IN THE CIRCUIT COURT OF THE STATE OF OREGON
J STATE OF OREGON,
Plaintifl MOTION TO CONSOLIDATE
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vs. Court No. 23CR00379 & 23CR04264
5 EMILY PRICE REYNEK-E DA No. 0066080

Defendant
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The District Attomey respectfully requests that that Court enter an order consolidating ofthe above cases on
the following ground(s):
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JOINDER OF CHARGES
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x The offenses charged are ofthe same or similar character.
9 tr The offenses charged are based on the same act or transaction.

tr The offenses charged are based on two or more acts or ransactions connected together or
l0 constituting parts ofa common scheme or plan.
ll JOINDER OF DEFENDANTS
t2 tr The defendants are accomplices in the charged offense(s)
13 OnClickortaptoenteradate.mystaffcontacted,attomeyforthedefendant,todetermineifhe/sheopposed
the consolidation. As of Click here to enter text..m. today, the defendant's attomey has not contacted my office to
advise oftheir position regarding the consolidation. OR They are not opposed to the consolidation.
t4
Dated rhis 27th day ofJanuary, 2023
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Respectfully Submitted,
16 RON BROWN, District Attomey
op , Oregon
t7
lr- I
18 Ron B No. 791726
Di Attomey
l9 rbrown@clatsopcounfy. gov
Points and Authorities:

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oRS 132.560
oRS 136.060
2t State v. Tumidse , 359 Or 364 (2016
State v. Turner, 153 Or App 66 (1998)
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1 _ STATE'S MOTION TO CONSOLIDATE
Clatsop Coun| Disttict Attome!

749Commercial Street
P.O. Box 149
Astotia, Orcgon 97103 (503) 325-ESEI
8/2/2023 9:33 AM
23CR00379
1 C Lane Borg, OSB 850294

North Coast Public Defender
Astoria, OR 97103
3 T: 503.462.3774
Email: lane.borg@northcoastpublicdefender.org
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Plaintiff,
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vs. MOTION FOR CONTINUENCE OF TRIAL
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EMILY PRICE REYNEKE,
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Defendant
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COMES NOW the defendant, Emily Reyneke, with her counsel C Lane Borg,
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and MOVES the Court for an Order Setting Over the Trial, currently set for
14 August 14, 2023.
15 This is the first trial setting for the case and Ms Reyneke is out of custody.
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The District Attorney filed an Amended Complaint on July 12. 2023 changing
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the subsection of the statutory crime charged. Defense needs time to file
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motions to address the new filing.
20 Deputy District Attorney Scott McCracken does not take a position on this
21 motion.
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DATED this 2nd day of August 2023 ____C Lane Borg____
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C. Lane Borg, OSB # 850294
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MOTION FOR CONTINUENCE OF TRIAL - 1
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I, C Lane Borg, certify that on State v Reuneke 23CR00379 I have delivered a True
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5 Copy of the Motion and Order to Continue Trial to Scott McCracken, DDA by emailing a true
6 copy to
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8 Scott McCracken <smccracken@clatsopcounty.gov>
9 DATED this 2nd of August, 2023 C Lane Borg_____________

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11 C. Lane Borg, OSB # 850294

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MOTION FOR CONTINUENCE OF TRIAL - 2
3/4/2024 2:50 PM
23CR00379
2 COUNTY OF CLATSOP
3 STATE OF OREGON, Case No.: 23CR00379
4 Plaintiff,
5 vs. MOTION TO DISMISS
6 EMILY REYNEKE,
7 Defendant
9 1.
10 INTRODUCTION
11 Defendant moves the court to dismiss this action on the grounds that the District Attorney
12 Ron Brown and Deputy District Attorney Alex Thomas engaged in prosecutorial
13 misconduct, deliberately withheld exculpatory evidence; committed perjury and caselaw
14 now requires the court to dismiss cases if a public defender cannot be assigned within a
15 specific number of days.
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17 2.
18 FACTS
19 In December 2023, Defendant learned that Ron Brown and Alex Thomas deliberately
20 withheld exculpatory evidence from Lane Borg and Collette Cameron, previous public
21 defenders for the defendant. This includes footage from Officer Zack Stockton’s body worn
22 MOTION TO DISMISS - 1
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1 camera; letters from Heidi Wintermute, Grace Laman, Maritza Casarrubias, and Janelle
2 Wagner; and interview reports from Callen Sterling, Heidi Wintermute, Grace Laman,
3 Maritza Casarrubias and Janelle Wagner.
5 3.
6 In the body worn camera footage , Zack Stockton of the Astoria Police Department placed
7 his body worn camera on the workstation he was sitting at prior to initiating recording, but
8 then appears in video to adjust the camera so that the desktop phone and computer were in
9 full view of the camera.
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11 4.
12 Zack Stockton contacted Callen Sterling of the Oregon School Board Association. Ms.
13 Sterling has been attempting to misuse her title of “attorney” and represent/mislead
14 individuals that she is the attorney for the Astoria School District Board when statuatorily
15 she is not legally authorized to represent the Astoria School District. And, Astoria School
16 District does in fact have a legally retained attorney of record named Richard Cohn-Lee.
17 Zack Stockton did not inform Ms. Sterling that he was recording the conversation.
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19 5.
20 On November 9, 2022 Haley Percell of the Oregon School Board Association, without
21 authorization from the Oregon School Board Association and without a legal basis, wrote
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1 a letter to Clatsop County District Attorney Ron Brown to attempt to pressure Mr. Brown
2 to prosecute the Defendant. This letter was withheld from defense counsel.
4 6.
5 On October 17, 2022 Grace Laman a school board member for the Astoria School District
6 knowingly and intentionally also wrote a letter to Mr. Ron Brown, to attempt to compel
7 Mr. Brown to prosecute the Defendant. Ms. Laman’s basis was “violation of public
8 meeting laws and sending inappropriate threats to elected public officials.”
9 However, Ms. Laman would proceed in her letter to state that the “threats” included “cost
10 the district millions”, “the entire school board will be recalled” and “also threatening to get
11 numerous district employees fired.” All of these threats prima facially are civil in nature
12 and not criminal acts. Additionally, elected board members of a public body such as the
13 Astoria School District are legally prohibited from using their position in the matter that
14 she did, and Ms. Laman is now at risk of prosecution and conviction for Official
15 Misconduct 1 et al.
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17 7.
18 On October 16, 2022 at 9:44 p.m. Maritza Casarrubias, another Astoria School District
19 Board member, officially wrote an email letter to Clatsop County District Attorney Ron
20 Brown via his non public email address that she obtained from Heidi Wintermute who in
21 turn obtained it from her husband Judge Kirk Wintermute without legal authorization to do
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1 so, in an effort to compel Mr. Brown to take action against the Defendant. However, Ms.
2 Casarrubias, like Ms. Laman, stated her reasoning to be based on misinformation and on
3 “emails” that contained civil “threats” statements that her and the board’s actions would
4 cost the school district “millions”; and “writing a letter to a board member’s employer in
5 hopes of getting her fired or dismissed from her place of employment.”
6 Ms. Casarrubias even stated, “As a Board Member, I am concerned that Ms. Reyneke will
7 not be prosecuted.”
8 Ms. Casarrubias’ actions could also result in her being prosecuted and convicted of Official
9 Misconduct 1 et al.
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11 8.
12 On October 16, 2022 at 6:00pm Janelle Wagner, an Astoria School District employee and
13 personal friend of Heidi Wintermute, wrote an email letter to Mr. Ron Brown stating, “I’ve
14 been told that you’re not planning to prosecute Ms. Reyneke.” Ms. Wagner unlawfully
15 used her official position and is subject to prosecution and conviction for Official
16 Misconduct as well as Collusion/Conspiracy. In addition, Ms. Wagner has no involvement
17 in the matter outside of the inappropriate/unlawful letter that she wrote. She is not a witness
18 or victim nor was she present for any meetings that the Defendant had with the Astoria
19 School Board.
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2 9.
3 On October 16, 2022 at 5:21p.m. Heidi Wintermute wrote an email letter to Ron Brown’s
4 non public email address to deliberately attempt to pressure Mr. Brown to prosecute the
5 Defendant. In the second statement of her email letter, Heidi Wintermute states, “I am
6 writing to you to encourage you to proceed with prosecuting Ms. Emily Reyneke…”.
7 Within Ms. Wintermute’s email letter she goes on to deliberately make false statements in
8 retaliation to having been notified of the Oregon Government Ethics Commission
9 investigation et al. Those blatantly false statements include but are not limited to the entire
10 paragraph of her email letter which contains “I was informed over the weekend that there
11 was a woman matching her description sighted taking pictures of a board member’s home
12 late last week. I reported this new information to your investigator today.”
13 However, at the time that Ms. Wintermute sent this letter she had direct knowledge of the
14 Defendant working/driving a transit bus for Sunset Empire Transportation District at the
15 alleged time and was physically incapable of walking by Ms. Wintermute’s home.
16 Additionally, no other board members have alleged that the Defendant did this, thereby
17 further showing that it did not occur and that Ms. Wintermute was lying in an attempt to
18 cause sufficient alarm to compel Mr. Brown to maliciously prosecute the Defendant.
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1 10.
2 Also in Ms. Wintermute’s email letter to Mr. Brown, Ms. Wintermute stated, “I know that
3 we are not the first school district in Clatsop County that Ms. Reyneke has targeted. She is
4 costing our school districts and community members money and time…” and “I implore
5 you to please help us stop this woman from continuing to cause havoc in Clatsop County
6 with her unreasonable and unlawful behavior.”
8 11.
9 On October 12, 2022 Defendant emailed Heidi Wintermute, Maritza Casarrubias, Grace
10 Laman, Jeanette Sampson, and Jenna Rickenbach a notice of intent to file claim via email
11 letter. It included documentation to show that they were making a series of tortious errors
12 that were correctable, and that if they failed to reverse their decision it could cost the
13 Astoria School District millions of dollars to fix what they could have and should have
14 fixed on their own. Communication is required by the Oregon Tort Claims Act.
15 Heidi Wintermute, Maritza Casarrubias, Grace Laman, Jeanette Sampson and Jenna
16 Rickenbach all had in their possession on October 12, 2022 a copy of the Oregon Bureau
17 of Labor and Industries Notice of Determination Letter involving the Seaside School
18 District. The bureau, herein referred to as BOLI, had made the legal determination that the
19 Seaside School District had unlawfully discriminated against a whistleblower which was
20 the defendant. This is the school district that Heidi Wintermute et al were referring to in
21 her email letter to Ron Brown.
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2 12.
3 On October 12, 2022 Callen Sterling told the Astoria School District Board that the Seaside
4 School District situation was “unfortunate” when asked about how Seaside handled the
5 defendant.
7 13.
8 Per the Oregon Government Ethics Commission, The topic(s) discussed in an executive
9 session must be limited to those topics expressly permitted by the specific provision(s)
10 under which the executive session was convened. Members of governing bodies may not
11 discuss topics in executive session other than those delineated in ORS 192.660 or other
12 state law permitting an executive session, even if the additional topics care related to the
13 issue concerning which the governing body convened the executive session. (OAR 199-
14 040-0220(1)).
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16 14.
17 The Astoria School District Board noticed it’s October 12, 2022 Executive Session under
18 ORS 192.660(2)(b) which states, “To consider the dismissal or disciplining of, or to hear
19 complaints or charges brought against, a public officer, employee, staff member or
20 individual agent who does not request an open hearing.”
21 The Astoria School District written policy which outlines how district employees can
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1 appeal a superintendent’s decision directs employees to file a grievance against the
2 Superintendent in order to appeal one of his decisions. As a result, the Classified staff union
3 rep instructs employees (and instructed the defendant) to file a grievance against Craig
4 Hoppes the Superintendent of the Astoria School District.
6 15.
7 The Oregon Government Ethics Commission and the Oregon Attorney General’s office
8 have administrative rules and policies which state that if an entity that is required to comply
9 with executive session rules and public meeting law does not follow the executive session
10 statutes to the letter, that any decision discussed in executive session has to be reversed and
11 there are no legal protections afforded if the executive session rules had been followed
12 exactly.
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14 16.
15 The Oregon Government Ethics Commission has already determined that the Astoria
16 School District Board only conducted one executive session and not two and that the
17 Defendant was invited to the executive session. .
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1 17.
2 The Astoria School District Board did not go into executive session properly, nor did it
3 properly publish that it was also going to go into executive session to confer with “legal
4 counsel”. Per the Oregon Government Ethics Commission and the Attorney General’s
5 Guidance on Executive Sessions, in order for any protections to be considered, the Astoria
6 School District Board would have had to have included in it’s notice of meeting and it’s
7 meeting agenda a citation of ORS 192.660 (2)(h) along with the wording that states, “To
8 consult with counsel concerning the legal rights and duties of a public body with regard to
9 current litigation or litigation likely to be held.” And, the school board would have had to
10 have audibly announced at the beginning of the executive session the ground(s) for entering
11 into the executive session for that reason. In fact, the Astoria School District Board did not
12 publish a public notice stating that they would be going into executive session to confer
13 with legal counsel and is not afforded any executive session or attorney-client protections,
14 and must reverse it’s decision to not investigate the complaint and decision of Craig
15 Hoppes further. The Board also did not announce when going into executive session for
16 the purpose of conferring with legal counsel under ORS 192.660(2)(h).
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18 18.
19 Callen Sterling is not legally authorized to represent the Astoria School District, nor is
20 the attorney of record for the Astoria School District.
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1 19.
2 For a number of years, Richard Cohn-Lee has been the retained attorney for the Astoria
3 School District. Richard Cohn-Lee has a conflict of interest in the matter involving the
4 Astoria School District. Richard Cohn-Lee now works for the Hungerford group in
5 Oregon City, Oregon as a partner in the law firm. Nancy Hungerford represented the
6 Seaside School District in a Oregon Bureau of Labor and Industry Complaint
7 Investigation involving the Defendant. The Seaside School District was officially found
8 by BOLI to have unlawfully discriminated against the defendant for whistleblowing and a
9 “Letter of Determination” was issued. Richard Cohn-Lee’s representation or input given
10 to the Astoria School District would be adversarial to both the Astoria School District and
11 the Seaside School District.
12 20.
13 On October 12, 2022 Ron Brown was alerted to a social media post by Heidi Wintermute
14 who was alerted to the social media post by a personal friend named Kali Linder, a personal
15 friend of Heidi Wintermute who is also a financial benefactor of the Astoria School District.
16 Mr. Brown interjected himself for the personal benefit of Heidi Wintermute and made
17 statements inconsistent with state law and caselaw on the social media platform Facebook.
18 Instead of requesting a District Attorney from a neighboring county review the matter, he
19 instructed Alex Thomas to handle the matter. However, Alex also has a conflict of interest
20 in that his landlord, Carol Toristoja, is a personal friend of Heidi Wintermute and an Astoria
21 School District employee.
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1 21.
2 On January 27, 2023 Ron Brown motioned for case 23CR04264 and this case to be
3 consolidated and asserted that the cases were similar in nature. On February 7, 2023 the
4 court granted that motion to consolidate.
6 22.
7 In June 2023 Deputy District Attorney Alex Thomas filed a motion to dismiss the
8 consolidated case and on July 7, 2023 that motion to dismiss was granted.
10 23.
11 In October 2023 the defendant in 23CR23294 filed a motion to dismiss her case. That case
12 was for the same alleged offense as Ron Brown and Alex Thomas are trying to allege here.
13 On October 27, 2023 Deputy District Attorney Alex Thomas filed a motion to dismiss in
14 that identical case, 23CR23294 State of Oregon v. Mary Eng. That motion to dismiss was
15 granted. Alex Thomas listed a reason within his response/motion to dismiss in that case,
16 however it made no mention of the reason being factual deficiencies. He listed the recent
17 9th Circuit ruling in his filing. However, during the course of the ongoing Oregon State Bar
18 investigation he has been trying to assert other reasoning to attempt to avoid accountability
19 and maintain legitimateness of this malicious case.
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1 24.
2 In 2023 Alex Thomas admitted in writing to the Oregon State Bar under penalty of
3 perjury that he had only “reviewed” the facts that had been given to him in the file
4 created by Ron Brown and Astoria Police Department. Alex Thomas failed to conduct a
5 thorough investigation and failed to gather all of the facts and caselaw that would have
6 irrefutably established that no crime had occurred and the case was without merit.
8 25.
9 Alex Thomas and Ron Brown are both currently facing Oregon State Bar
10 complaints/investigations which include what the Bar has identified as potential violations
11 regarding meritorious claims.
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14 26.
15 ARGUMENT
16 This case should never have been filed because the facts surrounding the issues do not
17 constitute a criminal act, even prima facially. This case is completely political in nature
18 and a deliberate attempt by Heidi Wintermute, Maritza Casarrubias, Grace Laman, Janelle
19 Wagner, Callen Sterling and Holly Percell to unlawfully compel Ron Brown to prosecute
20 the Defendant because the Defendant has evidence of their misconduct and torts and was
21 in the process of civilly whistleblowing against the Astoria School District, Heidi
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1 Wintermute, Maritza Casarrubias, Janette Sampson, Jenna Rickenbach, Callen Sterling and
2 Holly Percell; including the preparation of a civil complaint. Their letters, which Ron
3 Brown and Alex Thomas knowingly withheld from the Defendant and previous counsel
4 even though previous counsel had made several phone and email communications with
5 Ron Brown and Alex Thomas regarding discovery, are evidence of misconduct
6 (withholding of evidence et al) and criminal action on their part, but in terms of this matter
7 shows that their complaints did not have a basis in criminal law or that a crime allegedly
8 occurred.
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10 In State v. Neff, the Oregon Court of Appeals elaborated succinctly what constitutes a
11 violation of the Oregon Revised Statute that Ron Brown and Alex Thomas have been
12 attempting vainly to assert was violated. In State v. Neff, the court held that it does not
13 matter who establishes consent to record. It also held that once consent is established that
14 an indeterminate number of people could be surreptitiously recording and there is no
15 violation.
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17 28.
18 Because Ron Brown and Alex Thomas failed to thoroughly investigate and rather relied
19 solely on the slanderous misleading statements of Heidi Wintermute et al, they failed to
20 obtain the sign in sheet for the board meeting and executive session; they failed to identify
21 that Daily Astorian reporter Ethan Myers was present for the meetings and remained in the
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1 room during the entire executive session, and was recording executive session meeting as
2 he always customarily did; and they also failed to secure evidence to prevent spoiliation
3 that Astoria School District employee Marisa Flukinger was taking notes and recording the
4 meetings on her cell phone. When previous defense counsel Lane Borg emailed Alex
5 Thomas, Alex Thomas admitted in a reply email that he wasn’t aware that the Astoria
6 School District Board had recorded the October 12, 2022 Board Meeting; and, that he
7 would follow up with Officer Zach Stockton. Both Alex Thomas’ response and Zack
8 Stockton’s email response that he would contact the Astoria School District about it were
9 provided to the Defendant by Lane Borg. However, Zack Stockton never followed up with
10 the Astoria School District nor secured the evidence. Both the Astoria School District and
11 Ethan Myers recording the meeting each on their own establishes consent to recording.
12 Therefore, under State v. Neff there was no crime here. And, as a result, Alex Thomas,
13 even though he has vainly tried to assert that he personally “thoroughly” reviewed the case,
14 has continued to try to prosecute a case without merit that is a violation of state bar rules
15 AND highlights his widely known sloppiness towards detail that is known amongst area
16 attorneys. Plainly put, he never bothered to be thorough in gathering evidence and asking
17 enough questions to establish whether or not a crime occurred so ultimately it backfired.
18 Illustratively, if a subject is pulled over by law enforcement because a bystander called
19 police and smelled alcohol on someone, and the officer fails to gather information/evidence,
20 not only could the officer cause evidence to spoil because he didn’t collect it, but the subject
21 could be something completely different like an individual having a diabetic emergency.
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1 Just because someone says something, doesn’t preclude the officer nor the District
2 Attorney from their responsibilities to gather all of the evidence and not just stop and a
3 couple of purported statements made by the complainant(s). It’d be like that officer
4 arresting someone for DUI because someone said they smelled like alcohol without
5 gathering all of the information. And to add further foul, even though Alex Thomas did not
6 have all of the information, he negligently without merit continued to pursue the case
7 because of the inappropriate and illegal/criminal conduct of the complainants.
9 29.
10 Additionally, Facebook only maintains records requested by law enforcement for a period
11 of 90 days. However, neither Astoria Police Department nor Ron Brown nor Alex Thomas
12 secured the evidence directly from the source of Facebook of the alleged criminal act and
13 admitted to that in emails to previous defense counsel which were later conveyed to the
14 Defendant. Alex Thomas, Ron Brown, and Zack Stockton of Astoria Police Department
15 have all admitted to only having what Heidi Wintermute gave them on a flash drive but
16 never produced a copy of that flash drive in discovery to previous defense counsel in the
17 normal course of discovery and only after repeated requests, and is most likely spoiliated
18 for what minimal evidence that it may be. In fact, when the Oregon Government Ethics
19 Commission was investigating the Astoria School District (and will be restarting shortly),
20 the Ethics Commission requested Astoria School District’s recording of the October 12,
21 2022 Board Meeting. And, through City of Astoria attorney Blair Henningsgaard and not
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1 Astoria School District attorney Rich Cohn-Lee, Mr. Henningsgaard produced the
2 recording as the District’s recording but is also the same one that Alex Thomas keeps trying
3 to assert was made by the Defendant and a criminal act (which it is not).
5 There is absolutely no merit to this case. Plainly put, given State v. Neff and the alleged
6 facts in the charging document, the facts don’t constitute a crime and therefore should be
7 dismissed. This is nothing but 5 corrupt women who like to do whatever they want
8 whenever they want like they don’t make mistakes, and if anyone tries to bring up a mistake
9 or bad choice/decision/action/corruption they will do whatever is necessary to keep their
10 image how they want it even if it means breaking the laws themselves. They don’t like
11 whistleblowers and have themselves admitted to it. And they think because of who they
12 are and who they are married to that it makes them immune. Allowing this case to continue
13 would clearly continue to waste this court’s time, visiting judge’s time, be a gross
14 perversion of the laws, as well as violate the Defendant’s civil rights and legal rights.
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16 And, given that Ron Brown and Alex Thomas repeatedly withheld information and
17 exculpatory evidence that shows collusion amongst the purported victims/witnesses to
18 retaliate against the Defendant for whistleblowing is enough on it’s own to dismiss this
19 case. It wasn’t until a private investigator was hired that the exculpatory evidence was
20 uncovered. This requires immediate dismissal of this case.
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1 Furthermore, the 9th Circuit requires that the case be dismissed. The defendant has had two
2 public defenders, and the Defendant has made known to the court of issues with both of
3 those attorneys including one attorney being overloaded to the point of being negligent in
4 defense and another having personal opinions which conflicted with providing a defense
5 (as well as a conflict of interest which Colette Cameron brought up to the Defendant as a
6 conflict of interest). The court has been ignoring the Defendant when it comes to trying to
7 identify a public defender that can represent the Defendant and not have a conflict of
8 interest, that is available, and won’t further waste the court’s time and prolong the matter.
9 But then at subsequent hearings a name of a public defender is thrown out as the attorney
10 that is going to be assigned, but each time the court has not bothered to run simple conflict
11 checks. So now yet again, when the court threw out on the record the name of Paul Charas
12 as the one that they wanted the judge to assign to the Defendant, there is a major conflict
13 of interest that Paul Charas has brought up to the attention of the Defendant which is that
14 he was employed by the Clatsop County District Attorney’s office at the time of the alleged
15 incident as well as personally knowing several potential witnesses. So this issue is twofold.
16 Firstly, the assignment of a public defender and secondly the 9th Circuit.
17 Had the court clerks communicated with the Defendant about proposed public defenders
18 prior to hearings, the Defendant could have done simple searches or reflected on
19 knowledge base to determine whether a public defender had a conflict of interest. Secondly,
20 there are Defendants whose alleged crimes occurred prior to this case who do not have an
21 attorney and all of those cases are having to be dismissed because of the 9th Circuit ruling.
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1 By continuing to waste the court’s time and throw attorneys at a meritless case they are
2 violating the Defendant’s right to the application of the 9th Circuit decision and to have the
3 case dismissed because of that ruling.
5 Defendant now moves the Court to dismiss the case.
7 Please accept the electronically filed motion as a signed motion without a handwritten
8 signature. Defendant does not currently have the ability to print and to secondary scan
9 printed document to be efiled.
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11 Emily Reyneke
12 110 NW 4th St SPC D13
13 Warrenton, Oregon 97146
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8/8/2023 12:22 PM
23CR00379

Astoria, OR 97103
3 T: 503.462.3774
Email: lane.borg@northcoastpublicdefender.org
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Plaintiff,
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vs. DEMURR & MOTION TO DISMISS
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Defendant
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COMES NOW the defendant, Emily Reyneke, with her counsel C Lane Borg, and
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MOVES the Court for an Order Dismissing the Complaint pursuant to ORS 135.630 (4) for the
14 reason that ORS 165.540 has been struck down as unconstitutional by Project Veritas v Michael
15 Schmidt 9th Circuit No 22-35271, https://www.courthousenews.com/wp-content/uploads/2023/07/project-

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veritas-ninth-circuit-opinion.pdf
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Defendant requests oral argument on this motion.
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20 DATED this 8th day of August 2023 ____C Lane Borg____

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DEMURR & MOTION TO DISMISS
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5 I, C Lane Borg, certify that on State v Reyneke 23CR00379 I have delivered a True
6 Copy of the Motion and Order to Continue Trial to Alexander Thomas, DDA by emailing a true
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copy to
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9 Alexander Thomas<athomas@clatsopcounty.gov>
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DATED this 8th of August, 2023 C Lane Borg_____________
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DEMURR & MOTION TO DISMISS
7/21/2023 3:46 PM
23CR00379

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STATE OF OREGON,
Plaintiff', MOTION TO ALLOW
TELEPHONlC/VIDEO TESTIMONY
5 vs. FOR TRIAL
6
I
EMILY PRICE REYNEKE Court No. 23CR00379
Defendant.
DA No. 0066080
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COMES NOW the State of Oregon, by and through, Alexander A Thomas, Deputy District Attorney for
Clatsop County, Oregon, and respectfully moves the Court for telephonic/video testimony of Callen Sterling at the
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trial of the above matter now set for August 15, 2023. Said motion is based upon the facts set forth in the
10 accompanying affidavit, attached hereto, marked "Exhibit A", and incorporated herein by this reference.
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Dated this let day of July, 2023.
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Respectfully Submitted,
RON BROWN, District Attorney
13 for Clatsop County, Oregon
l4
15 fl/fl WWW/M
Alexander A Thomas, OSB No. 222324
Deputy District Attorney
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athomas@clatsopcounty. gov
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1

MOTION TO ALLOW TELEPHONIC/VIDEO TESTIMONY FOR TRIAL
Clatsop County DistrictAttarney

P. 0. Box I49
Astoria, Oregon 97103 (503) 325-8581
1

2
3
4 STATE OF OREGON,
Plaintiff, AFFIDAVIT FOR
TELEPHONIC/VIDEO TESTIMONY
5 vs. "Exhibit A"
6 EMILY PRICE REYNEKE Court No. 23CR00379

Defendant.
DA No. 0066080
7
STATE OF OREGON )
)ss.
9 County of Clatsop )
10 I, Alexander A Thomas, being first duly sworn on oath depose and say that:
11
I am the Deputy District Attorney prosecuting the above-referenced matter.
12
I have been contacted by Callen Sterling, an essential witness for the State, and they are unable to testify in
13
person due to being out of the country. On July 21, 2023 my office contacted C. Lane Borg, attorney for the defendant
14
and they have been in contact with the defendant and they do object to the telephonic/video testimony of Callen
Sterling.
15
Based on my review of the reports in this case, I believe the testimony of Callen Sterling will be necessary
l6
to prove the State's case.
17
18 fl/tx i/wmwj
Alexander A Thomas, OSB No. 222324
19 Deputy District Attorney
athomas@clatsopcounty.gov
20
SUBSCRIBED AND SWORN to before me this let day of July, 2023.
21
OFFICIAL STAMP
22
'N,
TRACY LEE REEDEB "Um Lu 1 LL lethal/L
NOTARY PUBLIC OREGON N Public
-
fir Oregon
COMMISSION NO. 1035735 C mmission Expires: April l6, 2027
23 MY COMMISSION EXPIRES APRIL 16. 2027
24
1
-
AFFIDAVIT FOR TELEPHONIC/VIDEO TESTIMONY "Exhibit A"
Clatsop County DistrictAttorney

P. 0. Bax I 49
Astoria, Oregon 97103 (503) 325-8581
CERTIFICATE TRUE COPY WELL FOUNDED IN LAW

I hereby certify that the foregoing copy of Motion to Allow TelephonicNideo
Testimony for Trial is a copy of the original. That the said pleading in my opinion is well
founded in law. I hereby certin that a foregoing copy was served on C. Lane Borg, attorney of
record for the defendant, on July 21, 2023 by method(s) as indicated below, pursuant to ORCP 9:
X Odyssey File & Serve to the email address provided by said attorney;
D USPS to the address provided by said attorney;
D Inter-office mailbox designated at the Clatsop County District Attomey's Office.
Dated this let day of July, 2023.
/s/Alexander A Thomas
District Attorney for Clatsop County

P. O. Box 149
Astoria, OR 97103
(503) 325-8581 Main Line
(503) 325-9305 Fax
daoffice@clatsopcounty.gov
Dawn L. Benthin
From: Nancy C. Lesiotis

Sent: Friday, April 5, 2024 1:36 PM
To: Dawn L. Benthin
Subject: FW: State vs. Emily Reyneke 23CR00379
Attachments: Re: State vs. Emily Reyneke 23CR00379
From: Emily Reyneke <csufiredog@gmail.com>

Sent: Friday, April 5, 2024 1:24 PM
To: Nancy C. Lesiotis <Nancy.C.Lesiotis@ojd.state.or.us>
Subject: Re: State vs. Emily Reyneke 23CR00379
WARNING: This email is from outside of the Oregon Judicial Department. If links or files in this email are
unexpected, even if from an email address you trust, please call the sender on the phone and verify them before
you click.
You shouldn't jump to conclusions and assumptions that are above you. If you continue to be a professional fool then
the State Court Administrator will be reviewing your conduct and employment and it won't be up to your buddies.
On Fri, Apr 5, 2024 at 1:20 PM Nancy C. Lesiotis <Nancy.C.Lesiotis@ojd.state.or.us> wrote:
Ms. Reyneke:
You have been told by Judge Benjamin and court staff not to send emails directly to a judge regarding your case. Any
communication must be filed with the court and copied to the state. As Judge Benjamin stated previously, she is not
reviewing any emails you send.
Thank you,
Nancy Lesiotis
Judicial Assistant For
Judge Amanda Benjamin
Lincoln County Circuit Court
225 W. Olive RM 303

1
Newport, OR 97365
541-265-4236 ext. 41020
Please make sure to use LNN.courtroom.303@ojd.state.or.us when emailing Judge Benjamin’s staff to
ensure a prompt response.
This communication may contain privileged, confidential, or other information exempt from disclosure under
applicable law. If you received it in error, please advise me and immediately delete or destroy the communication
and any attachments without further reviewing, copying, or disclosing the contents, Thank you.
--
"Success exists of going from failure to failure without loss of enthusiasm." - Winston Churchill
"Speak softly and carry a big stick; you will go far" - Teddy Roosevelt
"Keep your eyes on the stars, and your feet on the ground." - Teddy Roosevelt
"Far better is it to dare mighty things, to win glorious triumphs, even though checkered by failure...than to rank with
those poor spirits who neither enjoy nor suffer much, because they live in a gray twilight that knows not victory nor
defeat." - Teddy Roosevelt
2
l \
CODy
co
Incident Report: A20223288
Diéose: Yes CummtA: Of Friday, October 21, 2022
-2
Sex / Race
Peep? Involved: Phone/ Date
1"
'6: Citation/Charge/Offense
Name / Address Cell Phone DOB/ AGE Officer
Caution
lnvolgment
Susp'gt REYNEKE. Emily F W 12/18/1982 39 10/13/2022
1 10 NW 4th St D13 541 -530-1 21 6 Stockton
8 Warrenton, OR 541-846-8511
Mentiated SAMPSON, Jeanette Christine F W 1/2/1970 52 10/13/2022
5 723 LEXINGTON Ave 503-325-6229 Stockton

Astoria, OR 503-791-4135
Comi'éinant STERLING. Callen 9/9/1984 38 10/13/2022

1201 NE Court St 400 3143241938 Stockton
Salem, OR
I
Complainant WINTERMUTE. Heidi Renee F 6/25/1977 45 10/13/2022

970 BRIDGE VIEW Ct 541-556-5152 Stockton
ASTORIA, OR
RESTRICTED INFORMATION
Dissemination, distribution,
or copying of this document
Date: Page 2 of 2
for unauthorized purposes is Ctmmz'AJ Of: Friday, October 21, 2022
T0:
prohibited and unlawfixl.
By: 3'3 19:7; a: ,n \w 334'»? 31' ff

Case No: 23CR00379

State of Oregon
vs OPINION AND ORDER
Emily Reyneke RE: DEFENDANT’S MOTION TO
DISMISS
This matter came before the court on October 6, 2023, on defendant’s Demurrer and Motion to
Dismiss. Defendant appeared represented by Lane Borg and Alex Thomas appeared representing the
state. Defendant asserts pursuant to ORS 135.630(4) that the facts stated in the Amended Information
filed by the state do not constitute an offense following the decision in Project Veritas v. Schmidt, 72
F4th 1043 (9th Cir 2023).
Facts
Defendant attended a public school board meeting on October 12, 2022. During the meeting the
school board entered an executive session and required members of the public to leave the room. The
state alleges that the defendant began a recording on her cell phone and left her cell phone unattended
in the room to capture the executive session of the meeting. During this executive session, board
members were present in person and the board’s attorney participated by phone. The board members
were unaware of the cell phone recording. The state alleges that the defendant later posted the
recorded executive session on Facebook.
For these alleged actions the defendant was charged with three counts of criminal behavior
under ORS 165.540. On July 3, 2023, Project Veritas v. Schmidt was published. 72 F4th 1043 (9th Cir
2023). Project Veritas discussed the constitutionality of ORS 165.540(1)(c), which prohibits the
unannounced recording of in-person conversations in Oregon. The state filed an amended information
charging defendant with one count pursuant to ORS 165.540(1)(a) for recording the executive session
and one count pursuant to ORS 165.540(1)(e) for posting the recording on Facebook. These sections
read as follows:
(a) Obtain or attempt to obtain the whole or any part of a telecommunication or a radio
communication to which the person is not a participant, by means of any device,
contrivance, machine or apparatus, whether electrical, mechanical, manual or
otherwise, unless consent is given by at least one participant.
(e)Use or attempt to use, or divulge to others, any conversation, telecommunication or

radio communication obtained by any means prohibited by this section.
ORS 165.540.
Defendant asserts that Project Veritas invalidated the entirety of ORS 165.540 and her case must be
dismissed. The state asserts that Project Veritas only invalidated ORS 165.540(1)(c).
Analysis
In Project Veritas v. Schmidt, the United States Court of Appeals for the Ninth Circuit found ORS
165.540(1)(c) facially unconstitutional. Defendant argued at the motion hearing that because the court
in Project Veritas used “the statute” at times in their decision (instead of “the section” or “subsection”),
they intended to invalidate the entirety of ORS 165.540. For example, the court in Project Veritas states,
“Because we conclude that section 165.540(1)(c) and its exceptions constitute a content-based speech
restriction, we can uphold the statute only if it survives strict scrutiny.” Id. at 1058. The court also states,
“Applying Oregon law, we may not sever the exceptions because severing them would not render
section 165.540(1)(c) constitutional. Accordingly, we conclude that the statute is facially
unconstitutional.” Id. at 1068.
Despite the use of the word statute at points throughout the opinion, the entirety of the court’s
analysis in Project Veritas is focused only on ORS 165.540(1)(c). This court finds nothing within the
Project Veritas decision that substantiates the defendant’s position that the entire statute is
unconstitutional. The majority opinion clearly states, “we must determine the constitutionality of
section 165.540(1)(c) under the First Amendment. Id. at 1055–56. The opinion does not engage in any
discussion regarding other sections of ORS 165.540, let alone clearly invalidate those sections. The
dissent also summarizes the majority opinion by stating, “The majority strikes down all of section
165.540(1)(c) by making several unjustified leaps.” Id. at 1078. Finally, although the dissent takes time to
discuss the potential implications of the majority ruling, they do not discuss the implications of
invalidating anything outside of ORS 165.540(1)(c).
The defendant also argued that Project Veritas invalidated the entirety of ORS 165.540 because the
decision held that severability does not apply. The opinion does discuss severability at length however,
the defense misunderstands the purpose of this analysis. The court analyzed whether ORS 165.540(1)(c)
could be upheld as constitutional if the exceptions to it contained in ORS 165.540(5)(a) and (b) were
severed from the statute. They determined that severability does not apply because even without the
exceptions ORS 165.540(1)(c) would remain unconstitutional. The opinion does not state or suggest that
ORS 165.540(1)(c) cannot be severed from the remainder of ORS 165.540.
Conclusion
The ruling in Project Veritas held only ORS 165.540(1)(c) to be unconstitutional. Defendant is not
charged under ORS 165.540(1)(c). Defendant’s motion is DENIED.
Signed: 10/10/2023 8:36:14 AM
Case N0: 2 3 CRoo 379

State of Oregon
vs
COURT APPOINTED COUNSEL
RECOMMENDATION AND ORDER
AND
Emily Reyneke D LIMITED JUDGMENT
D SUPPLEMENTAL JUDGMENT
RECOMMENDATION
Based on the applicant's Declaration, I recommend the following. Applicant is:
X
Financially Eligible for court-appointed counsel
D Not Financially Eligible for court-appointed counsel Verifier: Henry Donnellan
D N o Recommendation Defendant is in custody and Date:
21612024,
did not complete an application
THE COURT ORDERS:

The applicant's request for court-appointed counsel is:
E
Approved Attorney: Paul Charas Phone: 503 191-08 51
D Denied
The contribution amount be: [Maximum Contribution Amount: $.00]
E Waived
D Ordered in the amount of $.00
MONEY AWARD
1. Judgment Creditor: State of Oregon PO Box 8% Astoria Oregon 9710'? -
2. Judgment Debtor: Emily Reyneke 110 NW 4th St D13 Warrenton OR 92146
Application Fee: $.00

Contribution Amount: $.00
Total Amount Awarded: $.00
Payment of the amounts listed are due as follows, payable to the State of Oregon:
D Amount ordered must be paid in full by
D Monthly payments of $ beginning on and each month thereafter until paid in full
Additional costs may be added to this Money Award without further notice or order of the court if this account is
assigned for collection or requires scheduled payments.
No person or public body other than Judgment Creditor is entitled to any part of this money award. Additional
costs may be added to this Money Award without further notice or order of the court if this account is assigned
for collection or requires scheduled payments.
This Judgment is entered solely to resolve issues related to payment of costs related to an application for a court-
aPPOinted attorney
2/6/2024 11-38-59 AM
0.4%?»-
(Jnler 7 .\('P Recmnmeudu[mu and Judgment ACP-('LT [('D L15 'zum)

Po Box 835 ASTORIA OREGON 97103
503.325.8555 H'I'rpz//www.COURTS.OREGON.Gov/COURTs/CLATSOP
Case Name: EMILY REYNEKE

Case Number(s): 23CR00379
Case Type (if other than criminal): Offense Misdemeanor
Order Appointing Or Denying Counsel And Ordering Payment
(To be completed by Judge)
The court orders the applicant's Request for Court-Appointed Counsel is:
X Approved
D Denied
Oregon Public Defense .

Commission is hereby appointed by the court, contingent upon further verificatlon.
The court orders the $20 Application Fee is:

D Ordered
E Waived
The court orders the Contribution Amount is:

D Ordered in the amount shown on the attached Limited/ Supplemental Judgment.
g Waived
Date
2/27/20241:06:04 PM fl
' w 1\
Circuit Court Judge Amfida Benjamin
ORAC
Counsel Appointed ORDY
Counsel Denied
IDEF-210:o7/o4 (rev 8/ 2020 JV lba) Order Appointing or Denying Counsel
Distribution Original
Court File Copies
Verification, Applicant, Accounting and/or Date Entry, Defense Counsel
PO BOX 835 ASTORIA OREGON 97103
503.325.8555 HTTP://WWW.COURTS.OREGON.GOV/COURTS/CLATSOP

Case Number(s): 23CR00379 and 23CR04264
Approved
Denied
Lane Borg is hereby appointed by the court, contingent upon further verification.
Ordered
Waived
Ordered in the amount shown on the attached Limited/Supplemental Judgment.

Waived
ORAC – Counsel Appointed ORDY – Counsel Denied
IDEF-210:07/04 (rev 8/2020 JV|ba) Order Appointing or Denying Counsel
Distribution Original – Court File Copies – Verification, Applicant, Accounting and/or Date Entry, Defense Counsel
Po Box 835 ASTORIA OREGON 97103
503.325.8555 H'I'rpz//www.COURTS.OREGON.Gov/COURTs/CLATSOP

Case Number(s): 23CR00379
X Approved
D Denied
Colette Cameron is hereby appointed by the court, contingent upon further verification.

D Ordered
X Waived

D Ordered in the amount shown on the attached Limited/ Supplemental Judgment.
E Waived
ORAC
Counsel Appointed ORDY
Counsel Denied
IDEF-21o:o7/o4 (rev 8/ 2020 JV lba) Order Appointing or Denying Counsel

Distribution Original
Court File Copies
Verification, Applicant, Accounting and/or Date Entry, Defense Counsel
State of Oregon Case No: 23CR00379

Plaintiff,
v. ARRAIGNMENT/ FIRST APPEARANCE ORDER
RE: Amended Information
Hearing Date: 08/02/2023
Emily Reyneke Judge: Amanda R. Benjamin (Video)
Defendant. Prosecutor: Scott McCracken (video)
Defense Attorney: C Lane Borg (video)
StandIn Attorney:
Interpreter:
Defendant is charged with: Obtain/Attempt to Obtain/Use Contents of Communications; Obtain/Attempt to Obtain/Use

Contents of Communications; Obtain/Attempt to Obtain/Use Contents of Communications
APPEARANCE RELEASE STATUS ATTORNEY

I:I In Person I:I In Custody IE Court Appointed
X Waived Appearance El Security Release El Retained
I:I Video IE Conditional Release I:| Waived
El Telephone E] Third Party Release I] Applying
I:I Failed to Appear E] Matrix Release I] Hiring
I:| Warrant Ordered El Cited to Appear
CHARGING INSTRUMENT ARRAIGNMENT TRULY NAMED
I:I Provided Copy E] Waived Reading E] Yes
I:| Waived Receipt El Waived Advise of Rights El No, correct name is:
El Previously Provided El Advised of Firearms Laws El No, correct date of birth is:
El Advised of Risk of Self-Representation
DEFENDANT PLEADS: RELEASE
[X Not Guilty I:I Security set at: El Excluded from Release Matrix
D Guilty IE Monitored Conditional Release Continued I] Book and Release
D No Contest I:| Recognizance Release I:| Waived 14 Day Rule
I:I Admits E] Third Party Release subject to approval El Waived 60 Day Rule
I:I Denies I:I Forced Release converted to Conditional
I] Conditional Release approved if the
following conditions are met:
I] Other:
NO CONTACT
X] No Contact with Alleged Victim(s): Heidi Wintermute; Jeanette Sampson; Jenna Rickenbach; Grace Laman;
Maritza Casarrubias
Defense Attorney, Lane Borg to file a Motion to Continue the trial based upon the amended information.
FUTURE COURT DATE! S!

Date: Time: Courtroom:
DCaseManagement Conference
IX] Docket Call 3, 2023
........A}igUSt 1:45 pm. 300
IZTI'IalTLfi August 15, 2023 _____
9:00
D.Crimine1$tatu.s.¢heek '
El
8/2/20239:13:42AM
n R' 1
.
.
Circuit Court Judge Amanda Benjamin
Order -
Arraignment/First Appearance-CLT (CD 02/2023)

Plaintiff,
V. ARRAIGNMENT/ FIRST APPEARANCE ORDER
on 2"'1 Amended Information
Emily Reyneke Judge: Amanda R. Benjamin
Defendant. Prosecutor: Alex Thomas by video
Defense Attorney: Colette M Cameron by video
Stand-In Attorney:
Interpreter:
Defendant is charged with: ObtainZAttempt to ObtainZUse Contents of Communications; ObtainZAttempt to ObtainZUse

Contents of Communications

I:I In Person E] In Custody IE Court Appointed
I:I Waived Appearance El Security Release El Retained
[Z Video IX] Conditional Release I:I Waived
D Telephone I] Third Party Release I] Applying
[I Failed to Appear I:I Matrix Release I:I Hiring
I:I Warrant Ordered I:l Cited to Appear
ARRAIGNMENT
E Provided Copy IE Waived Reading IE Yes
I:I Waived Receipt IE Waived Advise of Rights E] No, correct name is:
I:l Previously Provided El Advised of Firearms Laws El No, correct date of birth is:
El Advised of Risk of Self-Representation
DEFENDANT PLEADS: LEASE
X Not Guilty El Security set at: |:I Excluded from Release Matrix
I:I Guilty El Monitored Release El Book and Release
I: No Contest IX Conditional Release continued I:I Waived 14 Day Rule
I] Admits I:I Recognizance Release I:l Waived 60 Day Rule
I:l Denies El Third Party Release subject to approval
|:I Conditional Release approved if the
following conditions are met:
C] Other:
NO CONTACT
E No Contact with Alleged Victim(s): Heidi Wintermute; Jeanette Sampson; Jenna Rickenbach; Grace Laman;
Maritza Casarrubias
I:I Defendant must apply for the DUII Diversion Program Within 30 days.
Defendant shall have days to file motion(s) against pleadings.

FUTURE COURT DATE! SI
Date: Time: Courtroom:
I:I Case Management Conference
I:I Docket Call
D Trial
g Crlmlnal Status Check .. .. 2/1/ 24 3:39....12.-m- 200
I:I Attorney Status Check
11/29/2023 3:39:01 AM
m
Cirzifit Court Judge Am'anda Benjamin
230R00379 Fl LE D
FEB 1 0 2023
IN THE CIRCUIT COURT 01' 1111'. $1 ATI'S OF OREGONClatsop

Circuit Codrt
2
STATE OF OREGON,
Pluintil'f, ORDEI{ 'I'O CONSOLIDATE
\
Vs. Court No. 23('1100379 62 23CR04264
EMILY PRICE REYN EKE DA No. 0066080

Dcfendtmt.
Upoll Motion of the 5mm ol'Oregon and for good cause shown;
IT IS HEREBY ORDERED llml'thc cases designated above shall be consolidated for all future
)
proceedings)
SAN/wick- Ha ma'hflk é»: Sefc:«2x,-' «2d ,
Lliéikxe-lzg, 5:; 060%

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12
13
14
15
16
17
18
19
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21
22
23
24
I
ORDER GRANTING STATE'S MOTION TO CONSOLIDA'I'E
\\
Clublap Cormol DIS/Hr! Attorney
749 Conunerclal Sim!
\
\
l'.0. Box I49

Astoria. Urqum 97M? (50!) 325-858]
l
IN THE CIRCUIT COURT OF THE STATE OF OREG()N
FOR Tll E COUNTY OF CLA'I'SOI'
STATE OF OREGON.
Plaintiff] CERTIFICATE OF COMPLIANCE
WITH SLR 4.085
Vs.
Court No. 23CR00379 & 23cr04264
EMILY PRlCB REYNEKB
Defendant. DA No. 0066080
'
This proposed order orjudgment is ready for judicial signatttrc because: .
l. D Enclt opposing party affected by this order or judgment has stipulated to the order orjudgment, as
shown b)' eaclt opposittg party's signature on the document beittg submitted.
10
2. B Each opposing party affected by this order or judgment has approved the ordct' orjudgmcnt. as
shown by signature on the document being submitted or by written confirmation of approval sent to
me.
ll
3 D l of this order orjudgtnent on each part)' entitleti to service on Click or tap to
lntve served a copy
12
enter a date. by Delectronic service, E! US Mail. or D Other [enter type ol'servicei:
13
a. I] No objection has been served on me.
b. D I received objections that i could not resolve with a
part)! despite reasonable efforts to do
14
so. i have filed o copy of the objections i received and indicated which objectiorrs remain
unresolved.
15
c. El Afler'confcn'ing about objections. the objecting party has agreed to independentl)' file any
16 remaining objection.
d. E] Service is not required as the opposittg party's position in mentioned in the affidavit.
'
I7
4, UServicc is not required. Timf. lb
12,4)" lit Wt$
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5'" '00
Mtilt/00W SPAR/(L
Car; 11)
Kid"more- ?
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on ll
-
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('7 '7
I9 Dated this 27th day of January, 2023_
20
21
'w/Nw
Ron Bram ,<6§'B_rgo.x'79t726
District A orney
22 rbrown@cltttsopcounbngov
\24 I ~ CERTlFlCA'l'IE OF COMPLIANCE WITH SLR 4.085
Clttttap Emma! Dbl/(c! Ariana-y

7J9 ('mumerclal Street
P. 0. Bot [-19
Aslolln. Gregor! 97103 (50.9 325-858!
Case No: 23CR00379; 23CR04264

State of Oregon
MEMORANDUM ORDER
Plaintiff,
v. Hearing Date: May 12, 2023
Senior Judge Suzanne Chanti
Emily Price Reyneke Prosecutor: Ron Brown – video
Defendant. Defense Attorney: C Lane Borg - video
Stand-In Attorney:
Interpreter:
This case came before the court for Status Check Hearing.
Defendant appeared: In Person In Custody Video Telephone Failed to Appear
IT IS ORDERED:
This case shall be set: at Courtroom
Case Management Conference Docket Call: 8/03/2023 at 1:45
Release Hearing Trial: 8/15/2023 at 9:00
Probation Violation Hearing Motion Hearing
Sentencing Diversion Hearing
Plea and Sentencing Status Hearing
Other
RELEASE of defendant shall be:

Security release at $ Conditional Release Agreement / Continued
Security changed to $ Forced Release Converted to Conditional Release
Revoked/Security set at $ Third Party Release subject to approval
Other
DEFENDANT’S ATTORNEY OF RECORD,

is relieved of further representation of defendant.
MOTIONS shall be filed within 30 days.
shall prepare the order/judgment.
OTHER: Defendant may travel to Washington State to assist a friend.
May 12, 2023
Rev. 8.08; Ref. No: G203025867, LB|ba 12/18/18

IN THE CIRCUIT COURT 0F THE STATE 0F OREGON
Case No: 23CROO379
State of Oregon
MEMORANDUM ORDER
Plaintiff,
V. Hearing Date: April 4, 2024
Judge: Amanda Benjamin video-
Emily Reyneke Prosecutor: Alex Thomas video

-
Defendant. Defense Attorney:

Stand-In Attorney:
Interpreter:
Defendant appeared: D In Person D In Custody E Video D Telephone D Failed to Appear

IT IS ORDERED:
E This case shall be set: May 9, 2024 at 8:30 a.m. Courtroom
D Case Management Conference D Docket Call: at
D Release Hearing D Trial: at
D Probation Violation Hearing D Motion Hearing
D Sentencing D Diversion Hearing
D Plea and Sentencing E Status Hearing
D Other

D Security release at $ D Conditional Release Agreement / Continued
D Security changed to $ D Forced Release Converted to Conditional Release
I
Revoked/ Security set at $ D Third Party Release subject to approval

I
Other
D DEFENDANT'S ATTORNEY OF RECORD,

D MOTIONS shall be filed within 30 days.

D shall prepare the order/judgment.
OTHER:
4/5/2024 8:38:43 AM
Order Memorandum-CLT (CD 01/2024)

Case No: 23CROO379
State of Oregon
MEMORANDUM ORDER
Plaintiff,
V. Hearing Date: November 2, 2023
Judge: Amanda Benjamin Video -
Emily Reyneke Prosecutor: Alex Thomas video-
Defendant. Defense Attorney: C Lane Borg

Stand-In Attorney:
Interpreter:
This case came before the court for Docket Call Hearing.
Defendant appeared: D In Person D In Custody D Video X Telephone D Failed to Appear

IT IS ORDERED:
E This case shall be set: November 29, 2023 at 8:30 a.m. Courtroom
D Plea and Sentencing E
Status Hearing
D Other
D RELEASE of defendant shall be:

I

I
Other
E DEFENDANT'S ATTORNEY OF RECORD, C. Lane Borg

D MOTIONS shall be filed within 3o days.

OTHER: Colette Cameron is appointed to represent the defendant. Defendant authorizes Mr. Borg to
release his file to Colette Cameron. The trial on November 15, 2023 shall be cancelled.
11/2/2023 2:44:19 PM
Oil-HIE Court JudEAm'Enda Benjamin
Rev. 8.08; Ref. N016203025867, LB|ba 12/18/18

Case No: 23CR00379
State of Oregon
MEMORANDUM ORDER
Plaintiff,
v. Hearing Date: August 3, 2023
Judge: Amanda Benjamin Video

Emily Reyneke Prosecutor: Sarah Shepherd video

-
Defendant. Defense Attorney: C. Lane Borg Video -
StandIn Attorney:
Interpreter:
This case came before the court for Docket Call Hearing.
Defendant did not appear.
IT IS ORDERED:
X This case shall be set: at Courtroom
D Case Management Conference E Docket Call: 11.02.2023 at 1:45 p.m.
D Release Hearing E Trial: 11.14.2023 at 9:00 a.m.
D Probation Violation Hearing D Motion Hearing (To be set with a Visiting Judge)
D Plea and Sentencing D Status Hearing
D Other
E RELEASE of defendant shall be:

D Security release at $ E Monitored Conditional Release Agreement Continued
D Revoked / Security set at $ D Third Party Release subject to approval
D Other

OTHER: Court grants the defendant's motion to continue the trial set for August 15, 2023.
8/3/2023 3:41 :34 PM
Qxw
Rev. 8.08; Ref. No: 6203025867, LB| ba 12/18/18

/
FILED
FEB 1 0 2023
: FOR THE COUNTY or CLATSOP
)
_Verified Correct Copy of Original 2/10/2023.

Clatsop Circuit Court
State of Oregon '
Case No: 23CRo4264 and 230R00379
Plaintiff,
Hearing Date: 02/ 10/2023

Emily Price Reyneke Judge: Martin E. Stone ~ u l deo
, Defendant. Prosecutor: Sarah Shepherd by video
Defense Attorney: Lane Borg by video
DEFENDANT IS CHARGED WITH: Obtairi [Attempt to ObtainlUse Contents of Communications; ObtainZAttempt to

ain Use nts of C ununicati ns se 2 C '
Obtain At em t Obt in Use 0011 ents of
Communications; ObtainZAttempt to ija
jnlUse Contents 9: Cgmmum'gfi ions [Case 230R00329)
APPEAm 9E ELME STATUS '

ATTORNEY
D In Person [I
In Custody Court Appointed
I] Waived Appearance El Security Release ,
I] Retained
[X] Video El Conditional Release [:1 Waived
1:] Telephone I] Third Party Release E] Applyiiig
I] Failed to Appear .
'
El Matrix Release E] Hiring

[:I Warrant Ordered [:I Cited to Appear
MGNMENT CHARGI ENT TRU AMED

Waived Reading [:1 Provided Copy Yes
E Waived Advise of Rights [:1 Waived Receipt D No, Correct name is:
El Advised of Risk of Self-Representation [3 Previously Provided
I] Advised of Firearms Laws [:1 No, Correct Date of Birth is:
k
QEFENDANT PLEAD§; RELEASE
X Not Guilty I] Security set at: Book and Release within 7 days
I: Guilty .
Conditional Release Agreement signed from 2/ 16/ 2023
I: No Contest E] Conditional Release Agreement continued [:1 Waived 60 Day Rule
D Admits E},Security Release continued I] Excluded from the Matrix
I] Denies [3 Third Pai'ty Release subject to approval
I] Forced Matrix Release converted to Conditional Release
I] Conditional Release upon verification of alternate residence or treatment
[I Conditional Release approved if the following conditions are met:
NQ CONTACT
E No Contact with Alleged Victim(s): Susan Farmer; Jeffrey Hazen; Paul Lewicki 230Ro4264; Heidi Wintermute,

Jeanette Sampson, Jenna Rickenbach, Grace Laman, Maritza Casarrubias
23CR00379
NEXT SCEEQULED COURT DATE

Hearing Type: Case Management Conferelioe
Hearing Date, Time, and Location: 3/24/23 at 8:30 am. in Courtroom 100 .-
//
//
//
//
The following victims were added on the Court record to case 230R00379: Heidi Wintermute, Jeanette Sampson, Jenna
Rickenbach, Grace Laman, Maritza Casarrubias. State and defense counsel agreed to remove the following victim from
Verified Correct Copy of Original 2l10/2023.
case 23CR04264: Stephanie Rodriguez.
Court grants the State's Motion to Consolidate, the State shall prepare the Order to Consolidate.
Defendant is ordered to complete the Court Appointed Attorney application process by Monday, February 13, 2023, at
5:00 pm. the defendant is ordered to pay the Court Appointed application fee of $20.00. Defendant is also ordered'to
report to pretrial release to arrange date and time to be booked and released. Defendant shall complete the book and
release process within 7 days from e date of February 10, 2023.
(b
(O
W1 ll'VCi'LLA (f Sfifm;
(I C (/LCUt f" (owe ("1 J'a Dc;
PO BOX 835 Astoria Oregon 97103
State of Oregon Case No: 23CRO4264; 23CR00379

Plaintiff,

Emily Price Reyneke Judge: Jonathan Hill by Video
Defendant. Prosecutor: Sarah Shepherd by Video
Defense Attorney:
DEFENDANT IS CHARGED WITH: ObtainZAttempt to ObtainZUse Contents of Communications;

ObtainZAttempt to ObtainZUse Contents of Communications {Case 23CRO_426_4 l; ObtainZAttempt to
ObtainZUse Contents of Communications; ObtainZAttempt to ObtainZUse Contents Of Communications [Case
23CR00329);
D In Person D In Custody D Court Appointed
D Waived Appearance D Security Release D Retained
E Video D Conditional Release D Waived
D Telephone D Third Party Release D Applying
D Failed to Appear D Matrix Release D Hiring
D Warrant Ordered D Cited to Appear
ARRAIGNMENT CHARGING INSTRUMENT TRULY NAMED
D Waived Reading D Provided Copy D Yes
D Waived Advise of Rights D Waived Receipt D No, Correct name is:
D Advised of Risk of Self-Representation D Previously Provided
D Advised of Firearms Laws D No, Correct Date of Birth is:
D Not Guilty D Security set at: D Book and Release
D Guilty D Conditional Release Agreement signed D Waived 14 Day Rule
D No Contest D Conditional Release Agreement continued D Waived 6o Day Rule
D Admits D Security Release continued D Excluded from the Matrix
D Denies D Third Party Release subject t0 approval
D Forced Matrix Release converted to Conditional Release
D Conditional Release upon verification of alternate residence or treatment
D Conditional Release approved if the following conditions are met:
NO CONTACT
D No Contact with Alleged Victim(s): Stephanie Rodriguez; Susan Farmer; Jeffrey Hazen; Paul Lewicki
NEXT SCHEDULED COURT DATE

Hearing Type: Arraignment
Hearing Date, Time, and Location: 2/ 10/ 23 at 8:15 a.m.
The defendant declared a conflict with the attorneys in the Kaino Law Group and declined to be arraigned with Mr.
Colwell as the stand in attorney. Defendant requests a Court Appointed attorney and will complete the application process
after the next scheduled hearing. The Court will appoint Lane Borg 503462-3774 to represent the defendant.
2l8l2023 7:53:02 AM
C/éflcuit Conn Judge Jonathan R. Hill
CLT_ARPD. 09/09/20". m' 10/21/20bnllv

23CR00379
1 PaulJ Charas, OSB 183207

Law Office of Paul J Charas
Astoria, OR 97103
3 T: 503.791.0851
4
1N THE CIRCUIT COURT FOR STATE OF OREGON
5
6
THE STATE OF OREGON, Case No.1 23CR00379
7
Plaintiff,
VS. ORDER RE: ORDER

9
EMILY REYNEKE,
10
Defendant
11
This matter having come before this court upon the motion of defendant, Paul
12
13
J Charas, counsel and upon the records and files herein; NOW, THEREFORE, IT IS
14 ORDERED:
15 Paul J Charas is allowed to Withdraw from representation on this matter and will have no
16
further involvement.
17
D<] allowed
18
19 [ ] denied
20
2I26/2024 9:50:19 AM
21
22
Cit/(g7,
Circult Court Judge Amanda Benjamin
23
24
25
26
27
28
ORDER -
l
1
CERTIFICATE RE: COMPLIANCE WITH UTCR 5.100
2
I certify this judgment/order is ready for judicial signature because:
3
[ ] Service is not required under UTCR 5.100(I)(c) because the other party has been found in
4
5 default or an order of default is being requested with this proposed judgment/order; because this
6
judgment/order is submitted ex parte as allowed by statute or rule; or this judgment/order is
7
being submitted in open court with all parties.
[ ] Each Party affected by this judgment/order has stipulated to or approved the judgment/order,
10
11 as shown by the signatures on the judgment/order, or by written confirmation sent to me.
12
[ x] I have served a copy of this judgment/order and the Notice of Proposed Judgment/Order to
l3
all parties entitled to service. And:
14
[ ] No objection has been served on me within the allowed time frame.
15
[ ] I received objections that I could not resolve with the other party despite reasonable
16
17 efforts to do so. I have filed with the court a copy of the objections I received and indicated
18 which objections remain unresolved.

19
[ ] Afler conferring about objections, the other party agreed to file any remaining
20
objections with the court.
21
22
[ x] No response or waiting time is required.
23
24
25
DATED this 21st day of February, 2024 73ml fl 6%»
26
Paul J Charas, OSB #
183207
27
28
ORDER-2
23CR00379
I
1 STATE OF OREGON, I
Plaintiff, ORDER TO CONSOLIDATE

4
vs. court No. 23CR00379 & 23CR04264
5 EMILY PRICE REYNEKE DA No. 0066080

Defendant.
6
Upo[ Motion ofthe State ofOregon and for good cause shown;
8 IT IS HEREBY ORDERED that the cases designated above shall be consolidated for all future proceedings.
l0
l1
t2
l3
t4
15
t6
t7
l8
19
20
2tl
22
23
24
I - ORDER GRANTING STATE'S MOTION TO CONSOLIDATE
Clasop Count! District Aflofiet

719 Comfiercial Strcet
P.O, Box 149
Astoia, Oregon 97103 (50J) 325-8581
I
, IN THE CIRCUIT COURT OF THE STATE OF OREGON

3
STATE OF OREGON,
4
Plaintifl CERTIFICATE OF COMPLIANCE
WITH SLR 4.085
VS
Coun No. 23CR00379 & 23cr04264
6 EMILY PzuCE REYNEKE
This proposed order orjudgment is ready forjudicial signatue because:

8
l. D Each opposing party allected by this order orjudgment has stipulated to the order orjudgment, as
9 shown by each opposing party's signature on the document being submined.
l0 2. ! Each opposing party affected by this order orjudgment has approved the order orjudgnenl, as
shown by signature on the document being submitted or by written confirmation ofapproval sent to
me.
1l
3. tr I have served a copy of this order orjudgnent oneach parry entitled to service on Click or tap to
t2 enter a date. by trelectonic service, D US Mail, or O Other [enter q?e ofservice]:
I3
a. E No objection has been served on me.
b. tr I received objections that I could not resolve with a party despite reasonable efforts to do
t4
so. I have filed a copy ofthe objections I received and indicated which objections remain
uruesolved.
15
c. fl After conferring about objections, the objecting party has agreed to independently file any
remaining objection.
t6
d. ! Service is not required as the opposing party's position in mentioned in the affidavit.
t7
4. tr Service is not required. n- iJrrs IYnc ru
sWW ilo @. fi)11
5N At't n
l8
ot (LOA,'/f
t9 Dated this 27th day ofJanuary, 2023 ';{ct
ou[L (atou)vt| LL -
D
20
2t Ron Bro SB t726

District A me_v
)', rbrown@clatsopcounfy. gov
23
24 I - CERTIFICATE OF COMPLIANCE WITH SLR 4.085
Clatsop Coun,, Di$ cl Aflome!

719 Com ercial Slrcel
P.O, Box 149
Astotio, Otegon 9710J (503) J25-8581
23CR00379
I
) FOR THE COUNTY OF CLATSOP
3 STATE OF OREGON,
Plaintiff. ORDER TO CONSOLIDATE
4
vs Court No. 23CR00379 & 23CR04264
5 EMILY PRICE REN]EKE DA No.0066080

Defendant.
6
Upon Motion ofthe State ofOregon and for good cause shown;
8 lT lS HEREBY ORDERED that the cases designated above shall be consolidated for all future proceedings.
l0
tl
t2
l3
t4
l5
l6
t7
IE
l9
20
2t
),
,l
24
I . ORDER ORANTING STATE'S MOTION TO CONSOLIDATE
Cla6op Couny Dittrlct Atto.n.!

719 Commercial St .et
P.O. Box 149
Attoia, Orcgon 97103 (t03) 325-EStl
I
I
3
4 STATE OF OREGON,
Plaintiff. CERTIFICATE OF COMPLIANCE
I
WITH SLR 4.085
5 VS
Court No. 23CR00379 & 23cr04264
6 EMILY PRICE REYNEKE
7
This proposed order orjudgment is ready forjudicial signature because

8
L tr Each opposing party affected by this order orjudgment has stipulated to the order orjudgment, as
9 shown by each opposing party's signature on the document being submitted.
I0 2. E Each opposing pary affected by this order orjudgment has approved the order orjudgment, as
me.
ll
3. D I have served a copy ofthis order orjudgment on each party entitled to service on Click or tap to
t2
enter a date, by Eelectronic service, D US Mail, or D Other lenter t]?e of servicel:
13
a. E No objection has been served on me.
b. tr I received objections that I could not resolve with a party despite reasonable efforts to do
t4
so. I have filed a copy ofthe objections I received and indicated which objections remain
unresolved.
15
c.E After conferring about objections, the objecting party has agreed to independently file any
remaining objection.
16
d. E Service is not required as the opposing party's position in mentioned in the affidavit.
l7
4. D Service is not required
n- IhY iYnc ra
t8 gt(LOAi/f S;^[LL WW tJo @. tdLl
19
5N Ct"t ro
Dated th is 27th day ofJanuary, 2023
o!IL wDivL|LL. D
20
2I Ron Bro SB l'726

District A
)1 rbrown@c latsopcounty. gov
23
Clorsop Counly Distic, Aflone!

71 9 Corrrmercial Street
P,O. Box 119

Attotia, Orcgon 97103 (503) 325-lSBt
23CR00379
I
, IN THE CIRCUIT COURT OF THE STATE OF OREGON

3
4 STATE OF OREGON,
Plaintifl ORDER TO ALLOW
TELEPHON IC,lr'IDEO TESTIMONY
vs. FOR TRIAL
6 EMILY PRICE REYNEKE

Defendant. Coult No. 23CR00379
7
DA No. 0066080
8
The Couft being advised ofthe State's request for Callen Sterling to testiry by telephone/video at Hearing -
9 Trial Six Person Jury on August 15, 2023 at 9:00 am,
10 HEREBY:
1l GRANTS the motion as to Callen Sterling appearing by telephone/video, Courr having found good cause for
the witness's inability to testiry in person at trial.
t2
D DENIES the motion as to callen sterling appearing by telephone/video, court having not found good cause
l3 for the witness's inability to testiry in person at trial.
t4
15
l6
t7
l8
19
20
2t
22
23
21
I _ ORDER TO ALLOW TELEPHONICAr'IDEO TESTIMONY FOR TRIAL
Cla$op CounE Disttict Afiomey

749 Commercial Stpet
P.O. Box 119
Astoria, Oftgon 97103 (503) 325-8561
I

3
STATE OF OREGON,
4
Plaintifl CERTIFICATE OF COMPLIANCE
WITH SLR 4.085
5 YS
Court No. 23CR00379
6 EMII,Y PRICE REYNEKF-
Defendant DA No. 0066080
7
This proposed order orjudgment is ready forjudicial signature because

I
tr Each opposing party affected by this order orjudgment has stipulated to the order orjudgment, as
9 shown by each opposing party's signature on the document being submitted.
10 2. tr Each opposing party affected by this order orjudgment has approved the order orjudgment, as
me.
ll
3. X I have served a copy of this order orjudgment on each party entitled to service on July 31,2023
t2 by trelectronic service, ! US Mail, or tr Other [enter type of service]:
13
a. tr No objection has been served on me.
t4
b.X I received objections.
c. E After conferring about objections, the objecting party has agreed to independently file any
l5 remaining objection.
d. n The opposing parry's position is mentioned in the affidavit.
t6
4. n Service is not required.
t7
l8 Dated this 31st day ofJuly, 2023
19
/sr'Alexander A Thomas
20 Alexander A Thomas. OSB No. 222324
Deputy District Attorney
2t athomas@clatsopcounfy. gov
))
,1
Clatsop Cou,lt! Disttict Attometr

749 Commercial Strcet
P,O, Box 149
Astotia, Otegon 97103 (503) 325-E581
23CR00379
123456789

STATE OF OREGON, )
10 )
Plaintiff ) No. 23CR00379
ll )
) ORDER RE: MOTION TO
12 EMILY REYNEKE, ) WITHDRAW
)
l3 )
l4
15 This matter having come before this court upon the motion of defendant, Colette
16
M. Cameron, counsel and upon the records and files herein; NOW, THEREFORE, IT IS
l7
HEREBY ORDERED:
18
Colette M. Cameron is allowed to withdraw from representation on this matter and will
19
,, have no further involvement.
20
21
[X] auowed' Defendant did not appear for the hearing. The court finds that no
actual conflict of interest exists between Ms. Reyneke and the
22 denied. consortium attorneys. At this time, no attorney will be appointed to
[ ]
23
represent Ms. Reyneke. At her next hearing, defendant may request
another consortium attorney and the court will appoint one more time
24 in this case. This will be her third court appointed counsel. If Ms.
Reyneke declines to work with this attorney, she will need to retain
25 counsel of her choosing.
1/10/2024 8.56.52 AM
ORDER
Page
0.1%?"
'l
Colette M. Cameron. OSB#971694

P.0.Box 131. Tilamook. OR 97141 ccameronlangmail.com
(503)502-7554
CERTIFICATE RE: COMPLIANCE WITH UTCR 5.100
1234567009
I
certify this proposed judgment/order is ready forjudicial signature because:
[ ] Service is not required under UTCR 5.100(1)(c) because the other party has been
found in default or an order of default is being requested with this proposed judgment/order;
because this judgment/order is submitted ex parte as allowed by statute or rule; or this
judgment/order is being submitted in open court with all parties.
[ Each party affected by this judgment/order has stipulated to or approved the

]
judgment/order, as shown by the signatures on the judgment/order, or by written
confirmation sent to me.
[ Xhave served a copy of this judgment/order and the Notice of Proposed

] l
Judgment/Order to all parties entitled to service. And:

10 No objection has been served on me within the 3/7 day time frame.
[ ]
[ ] l received objections that l could not resolve with the other party despite
11
reasonable efforts to do so. have filed with the court a copy of the objections l received
l
12 and indicated which objections remain unresolved.

[ ] After conferring about objections, the other party agreed to file any remaining
13 objections with the court.
14
[X ] No response or waiting period is required.
15
DATED this lflfjday of December, 2023.
l6
C lette M Cam on, OSB#971694
17 Attorney for defendant, Emily Reyneke
18
19
20
21
22
23
24
25
26
Page 2 ORDER
Colette M. Cameron. OSB#971694

no. uox 131, Tuiamoox, on 57141 (503)502-7554
P0 Box 835 Astoria Oregon 97103

vs
Emily Reyneke ORDER OF RECUSAL
I recuse myself from service as a judicial officer on this case and any of its proceedings for the
following reason:
D I am a party to the case

D I have an interest in the outcome
I have personal knowledge
D I am related to a party or attorney
D I was a lawyer in the case
D Affidavit of prejudice has been filed
D A party is my former client and a conflict exists
D Other reason:
/
2/7/2023 10:11:21 AM
'
2/7/2023
Klrk Wlntennute, Circuit Court Judge
Clatsop, 08/2017, LMlba


vs
following reason:

D I have personal knowledge
E Other reason: My husband represents a victim
6/29/2023 8:47:04 AM
6/29/2023 fim ambfiu'
Sr. Judge Paula Brownhill


vs
following reason:

V Other reason:
2/8/2023 1:02:53 PM
Circuit Court Judge Dawn M. McIntosh


vs
following reason:

E Other reason:
2/9/2023 11:07:57 AM
February 9, 2023 75¢ EWM

Beau Peterson, Circuit Court Judge

230R00379 Fl LE D
FEB 1 0 2023
IN THE CIRCUIT COURT 01' 1111'. $1 ATI'S OF OREGONClatsop

Circuit Codrt
2
STATE OF OREGON,
Pluintil'f, ORDEI{ 'I'O CONSOLIDATE
\
Vs. Court No. 23('1100379 62 23CR04264
EMILY PRICE REYN EKE DA No. 0066080

Dcfendtmt.
Upoll Motion of the 5mm ol'Oregon and for good cause shown;
IT IS HEREBY ORDERED llml'thc cases designated above shall be consolidated for all future
)
proceedings)
SAN/wick- Ha ma'hflk é»: Sefc:«2x,-' «2d ,
Lliéikxe-lzg, 5:; 060%

/\\
___
10
(1 flat} T" (bgggliff -72( D C:
<
11
'
2~ iw- 33'
12
13
14
15
16
17
18
19
2()\
21
22
23
24
I
ORDER GRANTING STATE'S MOTION TO CONSOLIDA'I'E
\\
Clublap Cormol DIS/Hr! Attorney
749 Conunerclal Sim!
\
\
l'.0. Box I49

Astoria. Urqum 97M? (50!) 325-858]
l
IN THE CIRCUIT COURT OF THE STATE OF OREG()N
FOR Tll E COUNTY OF CLA'I'SOI'
STATE OF OREGON.
Plaintiff] CERTIFICATE OF COMPLIANCE
WITH SLR 4.085
Vs.
Court No. 23CR00379 & 23cr04264
EMILY PRlCB REYNEKB
'
This proposed order orjudgment is ready for judicial signatttrc because: .
l. D Enclt opposing party affected by this order or judgment has stipulated to the order orjudgment, as
shown b)' eaclt opposittg party's signature on the document beittg submitted.
10
2. B Each opposing party affected by this order or judgment has approved the ordct' orjudgmcnt. as
shown by signature on the document being submitted or by written confirmation of approval sent to
me.
ll
3 D l of this order orjudgtnent on each part)' entitleti to service on Click or tap to
lntve served a copy
12
enter a date. by Delectronic service, E! US Mail. or D Other [enter type ol'servicei:
13
a. I] No objection has been served on me.
b. D I received objections that i could not resolve with a
part)! despite reasonable efforts to do
14
so. i have filed o copy of the objections i received and indicated which objectiorrs remain
unresolved.
15
c. El Afler'confcn'ing about objections. the objecting party has agreed to independentl)' file any
16 remaining objection.
d. E] Service is not required as the opposittg party's position in mentioned in the affidavit.
'
I7
4, UServicc is not required. Timf. lb
12,4)" lit Wt$
l8 l'
5'" '00
Mtilt/00W SPAR/(L
Car; 11)
Kid"more- ?
.
on ll
-
.
('7 '7
I9 Dated this 27th day of January, 2023_
20
21
'w/Nw
Ron Bram ,<6§'B_rgo.x'79t726
District A orney
22 rbrown@cltttsopcounbngov
\24 I ~ CERTlFlCA'l'IE OF COMPLIANCE WITH SLR 4.085
Clttttap Emma! Dbl/(c! Ariana-y

7J9 ('mumerclal Street
P. 0. Bot [-19
Aslolln. Gregor! 97103 (50.9 325-858!
Case No: 23CR00379
State of Oregon
MEMORANDUM ORDER
Plaintiff,
v. Hearing Date: February 02, 2024
Judge: Amanda Benjamin video
Emily Reyneke Prosecutor: Alex Thomas- Video

StandIn Attorney:
Interpreter:
This case came before the court for Status Hearing.
Defendant appeared: D In Person D In Custody fi Video D Telephone D Failed to Appear

IT IS ORDERED:
X This case shall be set: 03.07.2024 at 8:30 a.m. Courtroom
D Plea and Sentencing fl
Status Hearing
D Other

D Other

OTHER: The Court orders the warrant in this case be recalled. The Court appoints Paul Charas to
represent the Defendant in this matter. A status hearing shall be set for March 7, 2024 at 8:30 a.m.
212/2024 9:12:21 AM
Order
Memorandum-CLT (CD 01/2024)

Plaintiff,
v. ARRAIGNMENT/FIRST APPEARANCE ORDER

Emily Price Reyneke Judge: Martin E. Stone
Defendant. Prosecutor: Sarah Shepherd by video
Defense Attorney: Lane Borg by video
DEFENDANT IS CHARGED WITH: Obtain/Attempt to Obtain/Use Contents of Communications; Obtain/Attempt to

Obtain/Use Contents of Communications (Case 23CR04264); Obtain/Attempt to Obtain/Use Contents of
Communications; Obtain/Attempt to Obtain/Use Contents of Communications (Case 23CR00379)

In Person In Custody Court Appointed
Waived Appearance Security Release Retained
Video Conditional Release Waived
Telephone Third Party Release Applying
Failed to Appear Matrix Release Hiring
Warrant Ordered Cited to Appear
ARRAIGNMENT CHARGING INSTRUMENT TRULY NAMED

Waived Reading Provided Copy Yes
Waived Advise of Rights Waived Receipt No, Correct name is:
Advised of Risk of Self-Representation Previously Provided ______________________
Advised of Firearms Laws No, Correct Date of Birth is:
______________________
Not Guilty Security set at: ___________________ Book and Release within 7 days
Guilty Conditional Release Agreement signed from 2/10/2023
No Contest Conditional Release Agreement continued Waived 60 Day Rule
Admits Security Release continued Excluded from the Matrix
Denies Third Party Release subject to approval
Forced Matrix Release converted to Conditional Release
Conditional Release upon verification of alternate residence or treatment
Conditional Release approved if the following conditions are met:
_______________________________________________
NO CONTACT
No Contact with Alleged Victim(s): Susan Farmer; Jeffrey Hazen; Paul Lewicki – 23CR04264; Heidi Wintermute,
Jeanette Sampson, Jenna Rickenbach, Grace Laman, Maritza Casarrubias –
23CR00379
NEXT SCHEDULED COURT DATE

Hearing Type: Case Management Conference
Hearing Date, Time, and Location: 3/24/23 at 8:30 a.m. in Courtroom 100
//
//
//
//
The following victims were added on the Court record to case 23CR00379: Heidi Wintermute, Jeanette Sampson, Jenna
Rickenbach, Grace Laman, Maritza Casarrubias. State and defense counsel agreed to remove the following victim from
case 23CR04264: Stephanie Rodriguez.
Court grants the State’s Motion to Consolidate, the State shall prepare the Order to Consolidate.
Defendant is ordered to complete the Court Appointed Attorney application process by Monday, February 13, 2023, at
5:00 p.m. the defendant is ordered to pay the Court Appointed application fee of $20.00. Defendant is also ordered to
report to pretrial release to arrange at date and time to be booked and released. Defendant shall complete the book and
release process within 7 days from the date of February 10, 2023.
Case No: 23CR00379
State of Oregon
MEMORANDUM ORDER
Plaintiff,
V. Hearing Date: February 01, 2024
Judge: Amanda R. Benjamin video
Emily Reyneke Prosecutor: Alexander Thomas Video -

StandIn Attorney:
Interpreter:
This case came before the court for Status Hearing.
Defendant failed to appear.
IT IS ORDERED:
D This case shall be set: at Courtroom
D Other
D Security release at $ D Conditional Release Agreement Continued
D Other
D MOTIONS shall be filed within 3o days.

OTHER: Defendant failed to appear. Court issued warrant. Security set at $15,000.00.
Court staff called defendant but she did not answer. Defendant was emailed notice to her for
remote appearance.
2/1/2024 8:46:05 AM
GA Ea»-
Order
Memorandum-CLT (CD 01/2024)
FORTHE COUNTY OF CLATSOP


Plaintiff, ASSIGNED JUDGE: N0 Judicial Officei' Assigned
v.
ORDER FROM
Emily Reyneke CASE MANAGEMENT
CONFERENCE
'
Defendant.
Defendant: E] In person I/Dy video I] By phone

Release Status: Agreement Monitored Release filed 2/10/2023
Defense Attorney: C Lane Borg [I In person X By video C] By phone
District Attorney: Marissa Snyder E] In person X By video [:1 By phone
FINDINGS AND ORDERS FROM HEARING ON 03/24/2023:

Date Filed: 01 03/2023 .,
4,.
'I_ f6":
.
Complex Case: M "I; ,'w'n (tit; {r "*3"

j
lurizw'"" 1.74.
..
Plea Offer Made: .r'YeS DN0 3; [11A, (tilt; 14 {ii/1,» ".5 y ifl'i.l..l ;*
SEI'Yes E! No
'
Discovery Complete: Discoverv Deadline

Motions to be Filed: D Yes [:1 No
,
HUnknown Motion Deadline:
Alleged Victim Notified: DYes I] No and wishes to be present at hearings: ElYes EINO
I] Considei' for Specialty Court
x'f f I '2
:(g'l
FUTURE PROCEEDINGS: 7: 13's '
,.
)
1/ 1.24m { !
I] None
Defendant FI'A/Warrnnt Issued: $
Appearance Type: Date: Time: Com'tl'oom:

El Plea & Sentencing
1:} Call & Trial Call
Trial
E] Qriminal Status Check
I'fiase Management Conference
1:] Defendant is in custody w/ recent 60-day waiver
E] Defendant has new charges filed
I] .efendant h ?§. new}
Ii
.
Other: 5'1??? 3""5-"3': 1

Afix 4"
'4 1: 5
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{,1 "122. {4« C
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1
I
-
ADDITIONAL ORDERS:
CLTORCMC, 2022-02-23, balDMM Page 1 of 1

Case No: 23CR04264 and 23CR00379
State of Oregon
MEMORANDUM ORDER
Plaintiff,
V. Hearing Date: April 20, 2023
Judge: Denise Keppinger
Emily Price Reyneke Prosecutor: Dawn Buzzard by video
Defendant. Defense Attorney: C Lane Borg by Video
Stand-In Attorney:
Interpreter:
Defendant not appearing.
IT IS ORDERED:
E This case shall be set: 5/12/23 at 11:30 a.m. Courtroom 200
D Other
X RELEASE of defendant shall be:

D Security release at $ E Conditional Release Agreement Continued
D Revoked/ Security set at $ D Third Party Release subject to approval
D Other

OTHER: Defendant did not appear. Defense counsel reported that defendant has been in good contact
and that she started a new job today and was unable to appear for today's hearing. N0 warrant ordered.
Defense counsel reports that they do not anticipate filing any motions. Counsel reports time needed for trial
is estimated to be 23 days. Parties will discuss a trial date at the next Court hearing. Parties are looking to
set trial dates sometime after the month Of August due to State and defense counsel unavailability in the
months of July and August.
4/20/2023 10:59:31 AM
4/20/2023
[WW
Circuit Court Judge Denise E. Keppingor
Rev. 8.08; Ref. No: G203025867, LBlba 12/18/18

Case No: 23CR00379; 23CR04264
State of Oregon
MEMORANDUM ORDER
Plaintiff,
v. Hearing Date: July 07, 2023
Judge: Sheryl Bachart
Emily Reyneke Prosecutor: Alex Thomas- Video
Defendant. Defense Attorney: C Lane Borg video -
StandIn Attorney:
Interpreter:
This case came before the court for Hearing.
Defendant appeared: D In Person D In Custody fi Video D Telephone D Failed to Appear

IT IS ORDERED:
X This case shall be set: at Courtroom
D Case Management Conference E Docket Call: 08.03.2023 at 1:45 p.m.
D Release Hearing E Trial: 08.15.2023 at 9:00 p.m.
D Other
g RELEASE of defendant shall be:

D Security release at $ E Conditional Release Agreement / Continued
D Other

OTHER: Defendant's request for new counsel shall be deferred until Docket Call on August 3, 2023. The
State shall be in contact with the Defendant's Attorney regarding any decisions that have been made on the
merits 0f the charges Pending in both eases. State to advise whether filinq motions to dismiss
7/7/2023 11:44:51 AM
Circuit urt Judge Sheryl Bachart
Rev. 8.08; Ref. No: 6203025867, LBlba 12/18/18

23CR00379

Astoria, OR 97103
3 T: 503.462.3774
Email: lane.borg@northcoastpublicdefenderorg
4
5
6
THE STATE OF OREGON, Case No. 23CR00379
7
Plaintiff,
8
VS. ORDER
9
10
Defendant
11
12
DEFENDANT'S motion for Continuence is Granted X Denied

13
14 ORDER setting a new trial date for November 14' 20.23

15
Trial Call November 2, 2023
16
8I3I2023 1:45:02 PM
17
18
19
0.1%-
20
21
22
23
24
25
26
27
28
ORDER -1
1 CERTIFICATE OF COMPLIANCE SLR 4.085
2
3
This proposed order or judgment is ready for judicial signature because
4
Deputy District Attorney Scott McCracken has received a copy of the proposed order and
5
takes no position.
6
8
DATED this 3rd day of August, 2023____C Lane Borg____
9
10
C. Lane Borg, OSB # 850294
12
13
15
16
I, C Lane Borg, Certify that on State v Reyneke 23CR00379 I have delivered a True
17
18 Copy of the propsed Order to Continue Trial to Scott McCracken, DDA by emailing a true copy
19 to
20
21 Scott McCracken <smccracken@co.clatsop.or.us>
22
23
DATED this 3rd day of August, 2023 C Lane Borg_____________
24

26
27
28
ORDER - 2
Case No: 23CROO379
State of Oregon
MEMORANDUM ORDER
Plaintiff,
V. Hearing Date: January 10, 2024
Judge: Amanda Benjamin
Emily Reyneke Prosecutor: Alex Thomas by video
Defendant. Defense Attorney: Colette M Cameron by video
Stand-In Attorney:
Interpreter:
This case came before the court for Hearing RE: Motion to Withdraw Attorney.
Defendant did not appear.
IT IS ORDERED:
E This case shall be set: 2/ 1/ 24 at 8:30 a.m. Courtroom
D Other
X RELEASE of defendant shall be:

D Security release at $ E Conditional Release Agreement Continued
Other


OTHER: Defendant did not appear; it was unclear if she had received notification of today's hearing;
No warrant ordered. Court grants attorney Colette Cameron's Motion to Withdraw.
1I10l2024 8:57:51 AM
Circ'u'it Court Judge Am'Enda Benjamin
Rev. 8.08; Ref. N016203025867, LB|ba 12/18/18

3/4/2024 2:50 PM
23CR00379
2 FOR THE COUNTY OF CLATSOP
3 STATE OF OREGON, Case No.: 23CR00379
4 Plaintiff,
5 vs.
6 EMILY REYNEKE,
7 Defendant
9 I certify that on February 21, 2024 at 1:36pm that I emailed a copy of the Defendant’s
10 Motion to Dismiss with Prejudice on Clatsop County assistant District Attorney Alex
11 Thomas, OSB#222324 at athomas@co.clatsop.or.us as well as
12 daoffice@clatsopcounty.gov.
13
14 Please accept the electronic filing as the signature of the Defendant, as the Defendant
15 currently does not have access to a printer/scanner.
16
17 Dated this 21st day of February, 2024
18
19 Emily ReynekeOS
20
21
22 CERTIFICATE OF SERVICE - 1
23
24
Emily Reyneke
110 NW 4th Street SPC D13
(541) 846-8511 [RE@EUVE@

Clatsop County Circuit Court
JUN 27 2023
By'
Astoria, Oregon 97103
Re: 23 CR0037 9 / 23 CR04264 / Motion to Dismiss / Public Defender
Your Honor,
I am writing for two reasons. Firstly, I am writing to motion the court to dismiss both
23CR003 79 and 23 CR04264. Both cases were maliciously and wrongfully filed for the
personal benefit of Jeff Hazen and Heidi Wintermute without merit, both of whom are
known to District Attorney Ron Brown. Mr. Brown has admitted to the Oregon State Bar
that he knows J eff Hazen and Heidi Wintermute as well as several other individuals
previously mentioned to the court that are connected to Sunset Empire Transportation
District and the Astoria School District. With respect to both cases, State v. Neff 246 Or.
App. 186 (Or. Ct. App. 2011)w0u1d be applicable. And, Mr. Brown's filings including
charging documents do not state facts sufficient to establish an allegation that a criminal
act occurred, because, in fact, no crime occurred. If this was a civil matter, this matter
would be dismissed with prejudice because it wouldn't survive an ORCP 21 motion.
Additionally, there are material flaws within the charging documents that show Mr.
Brown was attempting to manufacture meritless charges. In the Sunset Empire
Transportation District matter, Mr, Brown alleged that a criminal act occurred on
December 20, 2022 during a meeting. That is physically impossible to have occurred, as I
did not work for Sunset Empire Transportation District after December 9, 2022 and no
meetings of the SETD Board occurred between December 9, 2022 and it's January 2023
board meeting. Jeff Hazen also did not have the required authorization fro1n the Sunset
Empire Transportation District Board to make a report to law enforcement regarding the
matter but did so in retaliation for whistleblowing against him. In addition, Mr. Brown
had been communicating with Jeff Hazen prior to his filing of the baseless charges. Jeff
Hazen at the time knew that he was under investigation by Sunset Empire Transportation
District for misconduct M1 that the board was going to be considering disciplinary action
against him at it's February 15th, 2023 meeting when he emailed Deputy Chief Halverson
and communicated with Ron Brown. Jeff Hazen was in fact formally disciplined on the
15m of February by the Sunset Empire Transportation District Board and was suspended
Emily Reyneke
110 NW 4th Street SPC D13
(541) 846-8511
without pay for 3 days. And now, Jeff Hazen is no longe1' an employee of the Sunset
Empire Transportation District because he resigned before the Board could terminate his
employment.
With regards to the Astoria School District matter, there is again a material flaw with Mr.
Brown's charging document that warrants dismissal of the case with prejudice.
In that matter, Mr. Brown again alleged a date that physically was incapable of occurring.
Mr. Brown alleged that a criminal act had occurred on October 13, 2022 at a meeting.
When in fact the Astoria School district Board did not have a meeting on October l3,
2022 and I was at work at Sunset Empire Transportation District on October l3, 2022.
In addition, the Astoria School District has since admitted to the Oregon Government
Ethics Commission that they in fact recorded their October 12, 2022 meeting and
provided a copy of the recording to the OGEC.The recording was made on Marisa
Flukinger's cell phone that sat in plain View on the table where she sat in close proximity
to Heidi Wintermute. Marisa is the Board Secretary of the Astoria School District and
ASD Superintendent Craig Hoppes' administrative assistant. So even if Ron Brown tried
to haphazardly refile he would not be able to allege that a crime occurred because the
facts do not support even the filing of a charge because of State V. Neff.
Both cases should be dismissed with prejudice.
If the motion to dismiss is not granted, I am requesting a hearing about either squaring
Mr. Borg away or assigning me a new public defender. Mr. Borg has known about the
flaws, and has deliberately not done whatI have asked of him and instead wanted to wait
until trial to bring up the flaws because he thinks Ron Brown will just refile if he did
what I asked. And as a result, I do not feel that he can give adequate legal
advice/representation without correction by the court. Additionally, he stated at the last
hearing that he is in near daily contact with me and that is not true. Previously I did stay
in what anyone would perceive as good communication with him, just not "near daily".
However now, even in light of caseloads, he's become unresponsive and doesn't return
calls.
Sincerely,
lv ReJ/neke
CL: Km§£g§0q
Lamfial'

FOR THE COUNTY 0F CLATSOP
FMLURETOAPPEARWW
@©@
E
Warrant in the name of the State of Oregon for:
Emily Reyneke Case No. 23CRoo379
110 NW4th St D13 Offense Report #: A20223288
Warrenton OR 97146 -
> Arresting Agency: Astoria Police

Date of Birth: 12/ 18/1982 Height: 5 Ft. 7 In. Eyes: Hazel
Gender: Female Weight: 223 Lbs. Hair: Brown
'
Race: White State ID#:
Additional identifying information:

Type of Offense:
165.540 Obtain/Attempt to Obtain/ Use Contents of I
Misdemeanor Class A l
Communications
165.540 Obtain/Attempt to Obtain/ Use Contents of Misdemeanor Class A
Communications
Additional Statute:
Security Amount: 15,000.00 (10% required for release)
Warrant Issue Date: 02/01/2024
TO ANY PEACE OFFICER,
YOU ARE COMMANDED to arrest Emily Reyneke, and bring her before this Court. If this
J
Court is closed, deliver her into the custody of the ailor of CLATSOP County, Oregon.
Conditions:
Status: Active
February 1, 2024
RETURN OF SERVICE
The undersigned peace officer hereby certifies that he / she has executed the within Warrant by
arresting Emily Reyneke on (date)
Officer Name (printed) Officer's Initials

JEONEN _m=_m_.o he .38 32.8

FOR THE COUNTY 0F CLATSOP
FAILURE T0 APPEAR W
Warrant in the name of the State of Oregon for: Cd
Emily Reyneke Case No. 2 3 379

110 NW 4t11 St D13
Warrenton OR 97146
Offense Rep
£3 : 0223288
> Arresting Agency: Astoria Police
Date of Birth: 12/18/1982 Height: 5 Ft. 7 1n.- es Hazel
Gender: Female Weight: 22 Lb Brown
Race: White State ID#:
Additional identifying information:

Type of Offense: Q.)
165.550 Obtain/Attempt to Obtaimi" tsof Misdemeanor Class A I
K.
I
Communications
Obtain/Attempt t ontents of Misdemeanor Class A
165.540
Communications
Additional Statute: {
WWe
Security Amount: 15,000.00 (10% req ire for release)
Warrant Issue Date: 02/01/2024
TO ANY PEACE OFFICER,
YOU ARE COMMANDED to I' E ily Reyneke, and bring her before this Court. If this
Court is closed, deliver he 'nto the c J
tody of the ailor of CLATSOP County, Oregon.
Conditions:
\1
Status: Active
\'r
\_,
C\
a? 04%,
February 1, 2024
\ /
RETURN 0F SERVICE
CircuiTCoun Judge Amanda Benjamin
The unders i dp a e fficer hereby certifies that he / she has executed the within Warrant by
arresting Emily e on (date)
Officer Name (prin d) Officer's Initials

_Verified Correct Copy of Original 2/2/2024._

Emily Reyneke Astoria School District Whistleblower Retaliation Motion To Dismiss + Memorandum Regarding Failed Public Defense in Oregon

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Monitoring Level: Standard I] Enhanced Cl Intensive

State of Oregon Case No: 23CR04264 and 23CR00379

Judge / Court Clerk / Deputy Sheriff

20 2. Ms. Reyneke believes there is a conflict of interest in this matter because I am

Page 1 - decuration of colette cameron in support of motion to withdraw

8 penalty for perjury.

12 CBIette M. Cétﬁémn, oss#971694

1 Paul J Charas, OSB 183207

14 2. Upon reviewing initial discovery. I discovered that I have a conflict in this

15 case that requires a mandatory withdrawal pursuant to ORPC 1.7

20 removed as her attorney as soon as possible.

21 4. My client’s address is 110 NW 4th St #D13, Warrenton, OR 97146

5 DATED this 21st day of February 2024 _Paul J Charas____________

Page 1 — declaration of colette cameron in support of motion to withdraw

4. i request the court aiiow me to withdraw as defendant's attorney of record

5. My client's address is 110 NW 4'" St. #D13, Warrenton, OR.97146.

penalty for perjury.

DATED this W day of January, 2024.

Declaration and proposed Order RE: Attorney Vlﬁthdraw to:

17 athomas©clatsopcountv.qov Emily Reyneke

November 30, 2023

Re: State of Oregon vs Emily Reyneke

NOTICE OF SCHEDULED COURT HEARING

IMPORTANT NOTICE: PLEASE READ

Hearing Notice – Criminal Status Check-CLT (CD 06/2023) Page 1 of 3

Important! If you cannot appear by video,

 Wear clothing that is appropriate for court. Do not

Hearing Notice – Criminal Status Check-CLT (CD 07/2023) Page 2 of 3

Dear Colette M Cameron,

This case is set for a Hearing – Status Check on 02/01/2024.

Dear Clatsop Circuit Court Calendaring Department,

Please cancel the Hearing – Status Check on 02/01/2024 and set:

 Call and Trial

Attorney Signature: ______________________________ Date: _____________

Hearing Notice – Criminal Status Check-CLT (CD 07/2023) Page 3 of 3

FOR THE COUNTY OF CLATSOP

5 vs. Court No. 23CR00379

6 EMILY PRICE REYNEKE DA No. 0066080

Clatsop Coun! Dislticl Allo e!

l0 Trial Attorney: Alexander A Thomas, OSB No.222324

Clatsop Counlf Difiticl Altomer"

I hereby certiff that the foregoing copy of SECOND AMENDED INFORMATION is a

n USPS to the address provided by said attomey;

tr Inter-office mailbox designated at the Clatsop County District Attorney's Office

Dated this 27th day ofOctober,2023,

District Attomey for Clatsop County

FOR THE COI,JNTY OF CLATSOP

\:5 Court No. 23CR00379

E,VItLY PRICT] RI]YNEKE DA No. 0066080

9 Count 2: IN'|ERCEPTION OF COMMUNICATTONS (Class A Misdemeanor: ORS 165.540(e)) FPC#

l7 the off'ense(s) specified in the infonnation.

ll{ DATED: J uly 12.2023

method(s) as indicated below, pursuant to ORCP 9:

! USPS to the address provided by said attomey;

! Inter-office mailbox designated at the Clatsop County District Attorney's Office.

Dated this l3th day ofJuly.2023.

/s/ Alex Thomas

Attorney Signature: __________________ Date: _

15 97103. Judge Kirk and Heidi Wintermute reside at