Page 1 - DEFENDANTS’ RESPONSE TO PLAINTIFF’S OBJECTIONS TO DEFENDANTS’ EXHIBITS

AND WITNESSES

HJV/6931300-v1

Department of Justice

1162 Court Street NE

Salem, OR 97301-4096

(503) 947-4700 / Fax: (503) 947-4791

ELLEN F. ROSENBLUM

Attorney General

HEATHER J. VAN METER #983625

DIRK L. PIERSON #941281

Senior Assistant Attorneys General

Department of Justice

1162 Court Street NE

Salem, OR 97301-4096

Telephone: (503) 947-4700

Fax: (503) 947-4791

Email: Heather.J.VanMeter@doj.state.or.us

Dirk L. Pierson@doj.state.or.us

Attorneys for Defendants Robert Wayne Edwards and State of Oregon

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF OREGON

JUSTIN MICHAEL WILKENS,

Plaintiff,

v.

ROBERT WAYNE EDWARDS, in his

individual capacity; THE STATE OF

OREGON,

Defendants.

Case No. 6:14-cv-00907-MC

DEFENDANTS’ RESPONSE TO

PLAINTIFF’S OBJECTIONS TO

DEFENDANTS’ EXHIBITS AND

WITNESSES

Defendants respond to plaintiff’s objections to defendants’ exhibits and witnesses as

follows, using charts for ease of reference.

A. DEFENDANTS’ RESPONSE TO PLAINTIFF’S EXHIBIT OBJECTIONS

Defendants state as a preliminary matter that “prejudice” and “unfair prejudice” are not

the same thing. All evidence is prejudicial in the sense that the party offering the evidence hopes

it will rebut the opposing side’s evidence and argument. Unfair prejudice “lure[s] the fact finder

into declaring guilt [or liability] on a ground different from proof specific to the [claim or]

Case 6:14-cv-00907-MC Document 105 Filed 12/29/15 Page 1 of 17
Page 2 - DEFENDANTS’ RESPONSE TO PLAINTIFF’S OBJECTIONS TO DEFENDANTS’ EXHIBITS

AND WITNESSES

HJV/6931300-v1

Department of Justice

1162 Court Street NE

Salem, OR 97301-4096

(503) 947-4700 / Fax: (503) 947-4791

offense charged.” Old Chief v. United States, 519 U.S. 172, 180 (1997). In other words, the jury

must be tempted by the proposed evidence to decide a case on grounds different from those the

law requires. See generally, Merritt & Simmons, LEARNING EVIDENCE, pp. 71-72 (2d Ed.

Thomson Reuters 2012).

NO. EXHIBIT DESCRIPTION PLAINTIFF

OBJECTION

DEFENDANTS’ RESPONSE ADMITTED

201. State Police Video of

Wilkens Chase

None

202. State Police Policy 500.8 –

Use of Force – Rev 7/11/06

(WIL-OSP-861-868)

None

203. State Police Policy 502.7 –

Halting Vehicles High Risk

Stop Rev 3/8/94 (WILOSP-401-403)

None

204. State Police Policy 502.9 –

Violator Pursuit Rev

10/20/06

(WIL-OSP-0056-0063)

None

205. 8/3/12: Eugene Fire &

EMS Department – Incident

12027751 – Patient Care

Report (WIL-OSP-0157-

0160)

Objection:

hearsay within

hearsay

The second sentence of the first

page narrative can be redacted;

plaintiff’s statements to EMT are

not hearsay 801(d)(2) and

exceptions 803(1) and 803(4)

apply

206. 8/3/12: Affidavit of Deputy

Tim Ware – Agency 12-

5393

(WIL-OSP-0167-0174)

Objections:

relevance,

hearsay,

incomplete,

undue

prejudice

Affidavit of Probable Cause is

relevant if plaintiff disputes

probable cause existed or “lawful

arrest” (see Defendants’ Response

to Plaintiff’s MIL #2, incorporated

herein by reference); Fed. R. Evid.

801(d)(1) and 803(8) apply to the

document; defendant Edwards’

statement is not offered for truth

but to show he discussed the use of

force at the accident scene;

plaintiff’s statement is non-hearsay

801(d)(2); it is Deputy Ware’s

complete Affidavit of Probable

Cause (the affidavit refers to seven

attached pages) and the same was

produced by plaintiff to defendants

in discovery; there is no unfair

Case 6:14-cv-00907-MC Document 105 Filed 12/29/15 Page 2 of 17
Page 3 - DEFENDANTS’ RESPONSE TO PLAINTIFF’S OBJECTIONS TO DEFENDANTS’ EXHIBITS

AND WITNESSES

HJV/6931300-v1

Department of Justice

1162 Court Street NE

Salem, OR 97301-4096

(503) 947-4700 / Fax: (503) 947-4791

prejudice in using evidence to

respond to plaintiff’s arguments

207. OSP Incident Report 12-

256613 by R. Edwards

(WIL-OSP-0030-0038)

None

208. 8/3/12 – OSP Use of Force

After Action Report by R.

Edwards (WIL-OSP-0380-

0383, 0353-0362)

Objections:

relevance,

hearsay,

incomplete,

undue

prejudice

Use of Force Report is relevant if

plaintiff argues defendant Edwards

attempted to “cover up” use of

force, also relevant to qualified

immunity and justification

defenses; document is not offered

for truth but to show defendant

Edwards discussed the use of force

contemporaneously; also hearsay

exceptions 803(6) and 803(8)

apply; the document is complete;

there is no unfair prejudice in

using evidence to respond to

plaintiff’s arguments

209. Captain Robert Edwards

Notebook pages

(WIL-OSP-431-435)

None

210. 8/15/12: OSP Personnel

Complaint Report by A.

Heider

(WIL-OSP-366-0372, 0353-

0359, 0374-0376, 0380-

0383, 0379, 0384-0387,

0360-0362)

Objections:

relevance,

hearsay,

incomplete,

undue

prejudice

Personnel Report is relevant to

both plaintiff’s claims and

qualified immunity and

justification defenses (“reasonable

officer” standard) and if plaintiff

argues defendant Edwards

received letter of reprimand for not

reporting use of force to supervisor

until later the same day; hearsay

exceptions 803(6) and 803(8)

apply; the report is complete; there

is no unfair prejudice in using

evidence to support defendant’s

defenses and respond to plaintiff’s

arguments

211. 8/30/12 Lane County

District Attorney Letter re:

LT Rob Edwards’ Arrest of

Justin Wilkens, Incident

date August 3, 2012 (WILOSP-0039)

Objections:

relevance,

hearsay,

incomplete,

undue

prejudice

DA Letter is relevant if plaintiff

disputes probable cause existed or

“lawful arrest” (see Defendants’

Response to Plaintiff’s MIL #2,

incorporated herein by reference)

and is relevant if plaintiff argues

defendant Edwards attempted to

“cover up” a use of force and is

relevant to both plaintiff’s claims

and qualified immunity and

justification defenses (“reasonable

Case 6:14-cv-00907-MC Document 105 Filed 12/29/15 Page 3 of 17
Page 4 - DEFENDANTS’ RESPONSE TO PLAINTIFF’S OBJECTIONS TO DEFENDANTS’ EXHIBITS

AND WITNESSES

HJV/6931300-v1

Department of Justice

1162 Court Street NE

Salem, OR 97301-4096

(503) 947-4700 / Fax: (503) 947-4791

officer” standard); Fed. R. Evid.

801(d)(1) and 803(6) and 803(8)

apply to the document; the

document is complete (one page);

there is no unfair prejudice in

using evidence to respond to

plaintiff’s arguments

212. DPSST Public Safety

Officer Records of Robert

Edwards

(WIL-OSP-0896-0900)

None

213. Awards and Letters of

Appreciation/Commendatio

n to Robert Edwards (WILOSP-793-798)

Objection:

relevance

Defendants agree documents

reflecting commendations and

awards will not be admitted unless

plaintiff opens the door (see

Defendants’ Response to

Plaintiff’s MIL #15, incorporated

herein by reference)

214. 6/21/15: Response to

Wilkens’ Subpoena Duces

Tecum to Lane County

Sheriff’s Office

(WIL-LCSO-SUB-001-074)

Objections:

relevance,

hearsay,

incomplete,

undue

prejudice

LCSO non-photograph documents

are relevant if plaintiff disputes

probable cause existed or “lawful

arrest” (see Defendants’ Response

to Plaintiff’s MIL #2, incorporated

herein by reference); the

photographs are relevant to

plaintiff’s claims for damages; the

event detail is the

contemporaneous account of the

radio traffic of the incident and is

relevant to all claims and defenses

in the case; Fed. R. Evid. 803(6)

and 803(8) apply to the

documents; the documents are the

complete LCSO response to

plaintiff’s subpoena; the records

custodian certificate is for

authentication; there is no unfair

prejudice in using evidence to

respond to plaintiff’s arguments

215. Google Satellite Map of

Crow Road Objection:

“distance

incorrect”

This is not an evidentiary

objection, perhaps plaintiff objects

to foundation but defendants will

lay a proper foundation

216 -

239

Reserved for Impeached N/A

Case 6:14-cv-00907-MC Document 105 Filed 12/29/15 Page 4 of 17
Page 5 - DEFENDANTS’ RESPONSE TO PLAINTIFF’S OBJECTIONS TO DEFENDANTS’ EXHIBITS

AND WITNESSES

HJV/6931300-v1

Department of Justice

1162 Court Street NE

Salem, OR 97301-4096

(503) 947-4700 / Fax: (503) 947-4791

B. DEFENDANTS’ RESPONSE TO PLAINTIFF’S WITNESS OBJECTIONS

Defendants respond to plaintiff’s objections to each of defendants’ witnesses as follows.

1. EMT Jesse Bishop

As with response to plaintiff’s objections to exhibit 206 above, the second sentence of the

first page narrative can be redacted, but plaintiff’s statements to the EMT are not hearsay 801(d)(2)

and exceptions 803(1) and 803(4) apply.

2. Major Michael Bloom

Defendants incorporate their response to Plaintiff’s Motion in Limine #2 by reference as if

fully set forth herein. Defendants further state that Major Bloom’s testimony is relevant and

responds to plaintiff’s proposed argument that defendant Edwards was trying to “cover up” a use of

force, including the video matching defendant Edwards’ description and defendant Edwards

discussing the incident with others at the office. The testimony also responds to plaintiff’s proposed

testimony by the same witness Major Bloom that defendant Edwards failed to timely report and/or

was reprimanded for not reporting the use of force until a few hours later. Plaintiff objects that

testimony by Major Bloom regarding his belief that defendant Edwards simply forgot to report the

use of force is hearsay. This is inaccurate, hearsay is an out of court statement being offered for its

truth. Major Bloom is not proposing to testify regarding the content of statements except as

indicated.

3. Allen Edwards

Mr. Edwards will bring the records to court with him, which are business records

pursuant to 803(6).

4. Captain Robert Edwards

These objections simply re-state plaintiff’s MIL #2, 9, 14 and 17 (and 15 according to

plaintiff?), and defendants’ response to those motions is incorporated herein by reference.

Case 6:14-cv-00907-MC Document 105 Filed 12/29/15 Page 5 of 17
Page 6 - DEFENDANTS’ RESPONSE TO PLAINTIFF’S OBJECTIONS TO DEFENDANTS’ EXHIBITS

AND WITNESSES

HJV/6931300-v1

Department of Justice

1162 Court Street NE

Salem, OR 97301-4096

(503) 947-4700 / Fax: (503) 947-4791

5. Major Andrew Heider

These objections in part re-state plaintiff’s MIL #2, and defendants’ response is

incorporated herein by reference. Major Heider does not propose to introduce any out of court

statements by Sergeant Kenyon, rather he proposes to discuss his routine after-action

investigation including the steps taken and result, including referral to the district attorney’s

office. Plaintiff’s statements are not hearsay, 801(d)(2).

6. Senior Trooper Scott Hite

These objections in part re-state plaintiff’s MIL #2, and defendants’ response is

incorporated herein by reference. Plaintiff also objects that Trooper Hite was required to write

an expert report, however Trooper Hite was expressly designated as a 26(a)(2)(C) witness, and

his regular duties with the Oregon State Police are to coordinate and conduct training (not

provide expert testimony) regarding use of force and defensive tactics. Attachment A (Hite

Dep.) 5:24-6:18. The mere fact that plaintiff requested and defendants provided a 30(b)(6)

witness most knowledgeable on use of force training and tactics does not mean the person is

specially employed to testify as an expert. Indeed, plaintiff elicited testimony from Trooper Hite

that his job duties are coordinating and conducting training on defensive tactics. Id. Defendants’

disclosure meets the requirements of 26(a)(2)(C) and is admissible.

7. Sheriff Deputy Bryan Holiman

Plaintiff’s objection re-states plaintiff’s MIL #2, and defendants’ response is incorporated

herein by reference.

8. Sergeant Andrew Kenyon

Plaintiff’s objection re-states plaintiff’s MIL #2, and defendants’ response is incorporated

herein by reference. Plaintiff also objects to hearsay statements by defendant Edwards, however

the statements are offered as part of Sgt. Kenyon’s investigation and to show defendant Edwards

contemporaneously reported the use of force (see also defendants’ response to plaintiff’s

objections to exhibits 208, 210 and 211, incorporated herein by reference). Plaintiff’s statements

Case 6:14-cv-00907-MC Document 105 Filed 12/29/15 Page 6 of 17
Page 7 - DEFENDANTS’ RESPONSE TO PLAINTIFF’S OBJECTIONS TO DEFENDANTS’ EXHIBITS

AND WITNESSES

HJV/6931300-v1

Department of Justice

1162 Court Street NE

Salem, OR 97301-4096

(503) 947-4700 / Fax: (503) 947-4791

to Sgt. Kenyon are not hearsay, 801(d)(2). Sgt. Kenyon’s impression of plaintiff’s statement as

part of the after-action investigation, and that plaintiff was “setting up to sue” is routine and fair

testimony regarding plaintiff’s motive, intent and interest. Allan v. Cummings, 192 F. App'x

654, 655 (9th Cir. 2006) (42 U.S.C. §1983 claim against police, court stated “and the police were

entitled to probe the basis for her claim and her ‘motive’ or ‘intent’ for filing the instant action,

Fed.R.Evid. 404(b).”); see also defendants’ response to plaintiff’s MIL #12, incorporated herein

by reference.

9. Dr. Scott Kitchel

See defendants’ response to plaintiff’s MIL #31, incorporated herein by reference.

Attachment A (Peterson Dep.), 6:5-13.

10. District Attorney Patricia Perlow

Plaintiff’s objection re-states plaintiff’s MIL #2 and 14 and exhibit 211, and defendants’

response is incorporated herein by reference. Defendants do not understand plaintiff’s relevance

objection because plaintiff cites the Court Order finding probable cause relates to the facts and

circumstances within the officer’s knowledge. D.A. Perlow’s testimony or findings regarding

plaintiff’s attempt to elude and disposition of his citations are not 608 “character evidence” or

609 criminal conviction evidence. As noted in response to plaintiff’s MIL #2, plaintiff can

choose to open the door to this testimony or not.

11. Trooper Dave Peterson

Plaintiff’s objection re-states plaintiff’s MIL #2, and defendants’ response is incorporated

herein by reference. As with Trooper Hite, Trooper Peterson was expressly designated as

a 26(a)(2)(C) witness, and his regular duties with the Oregon State Police are to conduct training

(not provide expert testimony) regarding driving, high-risk and traffic stops, and previously

firearms. Attachment A (Peterson Dep.) 6:5-13. The mere fact that plaintiff requested and

defendants provided a 30(b)(6) witness most knowledgeable on these topics does not mean the

person is specially employed to testify as an expert. Indeed, plaintiff elicited testimony from

Case 6:14-cv-00907-MC Document 105 Filed 12/29/15 Page 7 of 17
Page 8 - DEFENDANTS’ RESPONSE TO PLAINTIFF’S OBJECTIONS TO DEFENDANTS’ EXHIBITS

AND WITNESSES

HJV/6931300-v1

Department of Justice

1162 Court Street NE

Salem, OR 97301-4096

(503) 947-4700 / Fax: (503) 947-4791

Trooper Peterson that his job duties are conducting training on violator pursuit driving. Id.

Defendants’ disclosure meets the requirements of 26(a)(2)(C) and is admissible.

12. Sheriff Deputy Tim Ware

Plaintiff’s objection re-states plaintiff’s MIL #2 and objection to defendants’ exhibits 206

and 214, and defendants’ responses are incorporated herein by reference.

DATED December 29 , 2015.

Respectfully submitted,

ELLEN F. ROSENBLUM

Attorney General

s/ Heather J. Van Meter

HEATHER J. VAN METER #983625

DIRK L. PIERSON #941281

Senior Assistant Attorney General

Trial Attorney

Tel (503) 947-4700

Fax (503) 947-4791

Heather.J.VanMeter@doj.state.or.us

Dirk L. Pierson@doj.state.or.us

Of Attorneys for Defendants State of Oregon

and Robert Wayne Edwards

Case 6:14-cv-00907-MC Document 105 Filed 12/29/15 Page 8 of 17
VMEOCONFERENCMG 

RFPORTII\ G& 

Scott Hite 

Wilkens v Edwards and State of Oregon 

- May- -5th, 2015 

CERTIFIED COPY 

CC REPORTING AND VIDEOCONFERENCING 

172 East 8th Ave 

Eugene, OR 97401 

541-485-0111 

www.ccreporting.corn 

ccreporting.com541-485-0111 

ATTACHMENT A, Page 1 of 9

Case 6:14-cv-00907-MC Document 105 Filed 12/29/15 Page 9 of 17
Scott Hite 

UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF OREGON 

EUGENE DIVISION 

JUSTIN WILKENS, ) 

) 

Plaintiff, 

v 

) 

) 

) No_ 14-CV-00907 

) 

ROBERT EDWARDS, in his 

individual capacity; 

) 

) 

THE STATE OF OREGON; 

) 

Defendants. ) 

DEPOSITION OF OREGON STATE POLICE 

30(b) (6) 

BY SENIOR TROOPER SCOTT HITE 

May 5, 2015 

Tuesday 

10:01 A.M. 

THE DEPOSITION OF SENIOR TROOPER 

SCOTT HITE, was taken at the Department of 

Justice, 1162 Court St. NE, Salem, Oregon, before 

Jan R. Duiven, CSR, FCRR, CCP, Certified Shorthand 

Reporter in and for the State of Oregon. 

CERTIFIED CON 

ccreparting.com541-485-0111 

ATTACHMENT A, Page 2 of 9

Case 6:14-cv-00907-MC Document 105 Filed 12/29/15 Page 10 of 17
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Scott Hite 

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A. z currently work out at the Oregon 

Public Safety Academy. The address out there is 

4190 Aumsville Highway Southeast, Salem, Oregon, 

97317. 

Q. Okay_ And what would be the best way 

to contact you by phone? 

A_ My work phone number is 503-378-4421. 

Q. Okay. 

MR. CAMPBELL: And, obviously, we 

represent Trooper Hite. So if you need him, go 

ahead and contact us. 

MS. REGAN: Of course. 

BY MS. REGAN: 

Q• And your date of birth, please? 

A. 5-24-1968_ 

Q. Okay. And your current -- well, yeah. 

Your current rank, please? 

A. Current rank is senior trooper. 

Q. Okay. And how long have you held that 

rank? 

A. For the last ten years. 

Q. Okay. 

A. Ten years. 

Q. And could you briefly explain to me 

like what your current chain of command is? Like 

ccreporting.com541-485-0111 

ATTACHMENT A, Page 3 of 9

Case 6:14-cv-00907-MC Document 105 Filed 12/29/15 Page 11 of 17
Scott Hite 

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where in the tree do you fall? 

A. I'm part of our training section. I'm 

the defensive tactics coordinator of the agency. 

My first-line supervisor is Jeff Lewis. He is the 

sergeant out at the training section. 

Q. Okay. 

A. And then there's a lieutenant that 

oversees that, and his name is Craig Flierl. 

Q. Okay. And so is it accurate to 

describe your position that you oversee all of the 

trainers that are actually providing training to 

police? 

Yes. 

Q. Okay. You yourself are not normally 

in the classroom or out actually providing 

training these days? 

A. No. I do both. I oversee and I still 

train. 

Q. Okay. 

A. And that's specific to Oregon State 

Police. 

Q. Right. Okay_ And is there a 

specialty area that you normally train in? 

A. No, 

Q. Okay. 

ccreporting.com541-485-0111 

ATTACHMENT A, Page 4 of 9

Case 6:14-cv-00907-MC Document 105 Filed 12/29/15 Page 12 of 17
Scott Hite 

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102 

State of Oregon 

) Os. 

County of Lane 

I, Jan R. Duiven, CSR, FCRR, CCP, a 

Certified Shorthand Reporter for the State of 

Oregon, certify that the witness was sworn and the 

transcript is a true record of the testimony given 

by the witness; that at said time and place I 

reported all testimony and other oral proceedings 

in the matter; that the foregoing transcript 

consisting of 101 pages, contains a full, true and 

correct transcript of the proceedings reported by 

me to the best of my ability on said date. 

If any of the parties or the witness 

requested review of the transcript at the time of 

the proceedings, correction pages have been 

inserted. 

IN WITNESS WHEREOF, I have set my 

hand and CSR seal this 18th day of May, 2015, in 

the City of Eugene, County of Lane, State of. 

Oregon. 

,g. 

Jan R. Duiven, CSR, FCRR, CCP 

CSR No. 96-0327 

Expiration Date: September 30, 2017 

ccreporting.com541-485-0111 

ATTACHMENT A, Page 5 of 9

Case 6:14-cv-00907-MC Document 105 Filed 12/29/15 Page 13 of 17
REPORTING(' 

VIDEOCONTERENCE\TGee 

• - • • • • • - • • • . •.• . .• . • • • . 

David Peterson 

Wilkens v Edwards and State of Oregon 

May 5th, 2015 

CERTIFIED COPY 

CC REPORTING AND VIDEOCONFERENCING 

172 East 8th Ave 

Eugene, OR 97401 

541-485-0111 

ww‘nLccreporting.corn 

ccreporting.com541-485-0111 

ATTACHMENT A, Page 6 of 9

Case 6:14-cv-00907-MC Document 105 Filed 12/29/15 Page 14 of 17
David Peterson 

UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF OREGON 

EUGENE DIVISION 

JUSTIN WILKENS, ) 

) 

Plaintiff, 

) 

) No. 14-CV-00907 

) 

ROBERT EDWARDS, in his 

individual capacity; 

) 

) 

THE STATE OF OREGON; ) 

) 

Defendants. ) 

DEPOSITION OF OREGON STATE POLICE 

30 (b) (6) 

BY SENIOR TROOPER DAVID PETERSON 

May 5, 2015 

Tuesday 

1:03 P.M. 

THE DEPOSITION OF SENIOR TROOPER 

DAVID PETERSON, was taken at the Department of 

Justice, 1162 Court St. NE, Salem, Oregon, before 

Jan R. Duiven, CSR, FCRR, CCP, Certified Shorthand 

Reporter in and for the State of Oregon. 

CERTIFIED COPY 

ccreporting.oam 541-485-0111 

ATTACHMENT A, Page 7 of 9

Case 6:14-cv-00907-MC Document 105 Filed 12/29/15 Page 15 of 17
matters of your personal knowledge, but also 

matters known or reasonably known to the Oregon 

State Police? 

A. Okay. 

Q. And I believe that you have been 

designated for OSP as a person that would know 

about the trainings and policies regarding driving 

and pursuit and traffic stops. Is that correct? 

A. I'm an EVOC instructor, so I've had 

advanced training in pursuit driving and 

high-speed driving, and S teach people --

remediate and teach new officers violator pursuit 

driving, yes. 

Q. Okay. Do you have any medical issues 

or medications that we should know about today 

that might impact your ability to answer questions 

honestly and completely? 

A. No. 

Q. Okay. Just some quick -- some general 

background questions. I assume you graduated from 

high school? 

A. I did. 

Q. Okay. And did you attend college or 

university? 

A. I did. 

David Peterson 

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David Peterson 

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77 

State of Oregon 

SS. 

County of Lane 

1, Jan R. Duiven, CSR, FCRR, CCP, a 

Certified Shorthand Reporter for the State of 

Oregon, certify that the witness was sworn and the 

transcript is a true record of the testimony given 

by the witness; that at said time and place I 

reported all testimony and other oral proceedings 

in the matter; that the foregoing transcript 

consisting of 75 pages, contains a full, true and 

correct transcript of the proceedings reported by 

me to the best of my ability on said date. 

If any of the parties or the witness 

requested review of the transcript at the time of 

the proceedings, correction pages have been 

inserted. 

IN WITNESS WHEREOF, 1have set my 

hand and CSR seal this 18th day of May, 2015, in 

the City of Eugene, County of Lane, State of 

Oregon. 

Jan R. Duiven, CSR, FCRR, CCP 

CSR No. 96-0327 

Expiration'Date: September 30, 2017 

ccreporting.com 541-485-0111 

ATTACHMENT A, Page 9 of 9

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