OWNER/ 

LESSEE 

'"':: :j .MOEN;;.:c:.JOD IE 

14941 VIREO DR 

PO BOX 92 

I 'BONANZA OR 

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/ 

I 

I 

RE AND COUNTERSIGNATURE OF SECURITY INTEREST HOLDER OR LESSOR RELEASING ALL INTEREST o·,:q_',.' 

NTERSIGNATURE OF SECURITY INTEREST HOLDER OR LESSOR RELEASING ALL INTEREST 

SEE REVERSE OF TITLE FOR APPLICATION INSTRUCTIONS. 

735-410 (5-oa) R793364 1ECSC2422X2394226 1434948108 X 

1048 062 04 V3 Tl 02 58 M6 PS EO MO 18 

OREGON 

FUEL TYPE EQUIPMENT NO. 

13 WEIGHT/LENGTH 

24 

' .(< ·- ODOMETER DATE 

4-- --·····--~-- _; ··-·- .·. EXHIBIT 

MOEN, JODIE I 

14941 VIREO DR 1i 

PO BOX 92 

BONANZA OR COUNTYOF 

RESIDENCE USE 

Case 1:15-cv-00380-CL Document 1-2 Filed 03/05/15 Page 1 of 4
K!a_math .County 

She;rifr s Office 

wt&Mb£*&ef &H¥WWWf+ •e 

AGENCYKCSO 

CAD EVENT 1501160062 

PRIORITY 3 

CALL TYPE THEFT THEFT 

SOURCE P 

LOCATION 14941 VIREO DR, BONANZA 

RP JODIE M0€..1~ 

COMMENT RESPOND T'? KCSO 

! iQWiiiJi& 

RESP: AREA 5S 

REPT. ZONE 

PHONE (541) 880-6990 

ZONE 5S 

RP STATE-~ THAT HER TRAILER WAS STOLEN FROM HER PROPERTY. RP STATES THAT SHE HAD AN AGREEMENT 

WITH A pUl'tl TO DO SOME WORK ON HER HOUSE FOR THE TRAILER IN RETURN, HE DID NO WORK FOR HER AND 

OOK HEP TP.AILER. POSS CIVIL MATTER 

T _ . ------[CAD3/52294 01/16/1512:35:00] 

ISSUED CASi3JI-15000109 FOR AGENCY KCSO by UNIT 4135 

E911 Received 

Created 01/16/15 11 b?:18 by 4197 at S01 

Dispatched 01/16/15 11·~:25 

En route 

Arrived 

Cleared 

Closed //-~----------··· 

01/16115 13;:Z?:36 

01/16/15 1 :;-::?:::'36 

CASE NUMBER 

ASSOCIATED NAMES 

Unit: Reason: RP Name: JJG€:-N, JODIE 

ASSOCIATED VEHICLES 

Unit: 4135 Reason: QV Ur~~: 103DUG 

0 Non-disclosure 

FINAL TYPE PRIMARY UNIT 4135 

UNIT STATUS Tl~ EVENT DIS PO CODE COMMENT/LOCATION 

4135 D 

4135 RL 

4135 RL 

4135 QV 

4135 c 

01/'l~,....t? 11:56:25 1501160062 

01/1'~---:? 12:00:30 1501160062 

0111'~,....:? 12:35:01 1501160062 

01/'7~<? 13:10:31 1501160062 

01/1~<? 13:20:36 1501160062 

o0"1-5130 ext-*8179 YbOne: (541) oo-r ..- . (541) 883-4271 ~ @CO klatnath.ot.US ~een · 

/14941 VIREO DR 

/KCSO OFFICE 

CASE# 15000109 FOR AGENCY KCSO 

CLEARED BY CAD2 

3300 Vandenberg Road 

Klamath Falls, OR 97603 

EXHIBIT 

I z -------------------~~~'!!!!!!!_ Page I 

Case 1:15-cv-00380-CL Document 1-2 Filed 03/05/15 Page 2 of 4
·- I 

January 12, 2015 

JODIE MOEN 

PO BOX 92 

BONANZA, OR 97623 

RE: Demand Letter 

Jodie: 

I have received your letters dated December 6, 2014 and January 3, 2015. As Ed and I are not only very 

confused by your letters, but very saddened, I will reply to you in writing so things are clear to all. 

Quite frankly Jodie, your letters are manipulative, inaccurate and confusing in that you know, and we 

know, what the truth of this situation is. Considering that we welcomed you into our lives and our home 

in an effort to help you in many ways over a long period of time makes your letters disheartening and 

disingenuous. We are saddened that you are now manipulating the situation to take advantage of our 

good nature even after all that we've done for you including but not limited to feeding and housing you 

at no cost to you. That being said, with the threats from you of legal ramifications, breach of contract 

and so on, I will address our stance as clearly as I am able. 

Ed never represented to you that he was a licensed contractor. You may claim that, but you simply 

know it's not true. What Ed did do, was offer to help a person who claimed to be down and out and 

claiming not to be able to afford someone else doing work for her. It was because of that, Ed offered to 

help you with various tasks at your "weekend cabin". Your continuous portrayal of no money and 

needing help resulted in Ed trying to help you the best way he knew how. It was agreed upon by the 

parties that, since you had no money to pay someone to do work you wanted done, we would exchange 

Ed's time as a handyman and money for materials for the 1999 Fleetwood Prowler. Accordingly, the 

verbal agreement was made for the trailer. 

With the above being said, Ed did the work YOU wanted him to do. Your letters confirm that Ed did in 

fact help you out in exchange for the trailer. Although you claim that Ed upset you during one 

conversation, that in itself is not a reason to breach a verbal contract that Ed had with you regarding the 

work exchange for the trailer. Ed performed numerous hours of work for you which far exceeded the 

value we discussed for the trailer. So from our stance, if the trailer goes back to you, the money is owed 

to us for services rendered. Additionally, the trailer being in our possession also indicates there was a 

transaction between the parties as otherwise, it would have never been placed with us. All parties 

involved know that you had us take the trailer's possession while you committed to get the title to us, 

which to date, you have not. Therefore, the only person who has breached our verbal contract is you. 

After much discussion with Ed, others who have been privy to and witnessed conversations with or in 

the presence of the parties and after reviewing your demand letters, here is what we are willing to do: 

EXHIBIT 

I 3-1 

Case 1:15-cv-00380-CL Document 1-2 Filed 03/05/15 Page 3 of 4
1. RETURN OF TRAILER: The trailer was given to us by you in exchange for work done and 

materials purchased for said work. Thus, it will not be returned unless you wr)te a check to us for $4000 

which is the figure discussed for handyman work done and materials needed to do that work. Ideally, 

we request that you follow through with the agreement and send the title to us forthwith but in lieu of 

that, we are willing to take the $4000 payment if that works better for you. Regarding you coming to 

take the trailer while this matter is pending, as there are no trespassing signs on our property, you will 

not be taking anything off of our property. We have not given you permission to do so and this is notice 

to you that you (or any representative of you) are not permitted to be on my property for any reason. 

As you have threatened legal action if we don't return the trailer, now would be a good time to seek 

that action if you are not agreeable to the above. 

2. RETURN OF POSSESSIONS: The possessions you mention are ones that have not been 

needed by you for numerous months and in fact, I'm not even sure what the actual possessions are. As 

we are uncomfortable with your many threats, let's handle all this through your upcoming legal action 

that you state you'll be taking. It is not our intent to keep them from you. It is our intent to not interact 

with you directly until these matters are resolved. Once resolved, we will arrange a time for you to pick 

up your possessions. At this point, I am not comfortable packing your items up for you and delivering 

as I do not trust that you will not claim something is missing or other false information like has been 

written in your letters. I am sure you understand my concern with that. 

3. UNLICENSED CONTRACTOR REPORTING: Many people assist friends, or so thought 

friends, with projects. Our relationship was that simple, until recently anyway. Ed helped you in 

exchange for the trailer. PERIOD. The irony in your threat is that you, with your "weekend cabin" and 

living arrangements, etc. are the one whom the government is likely more interested in. It is appalling 

that you would even accuse Ed and I of illegal actions when in fact it is you who is actually not following 

codes and laws and should be reported. You do what you feel you need to do as we are not afraid of the 

truth and will ensure the whole truth is set forth to the proper outside sources if needed. 

In conclusion, please send the title to us, per your original statements within ten days. If we do not 

receive it, or payment for Ed's handyman work and materials, we'll take your silence as an 

understanding that you will be promptly seeking legal action and we will await the proper notification of 

such. Also, as your letters refer to a "counsel" being given copies of your letters, I am sure that you are 

aware if you have retained an attorney in this matter, that said attorney's name should be given to us 

and all future contact between us shall cease and go through your "counsel". If you have not retained 

counsel, please do not include the reference to one as a pressuring tactic. Any response you have to this 

letter, should be in writing as we are no longer comfortable with verbal communication with you for 

obvious reasons. Ed and I look forward to resolving this made up issue as soon as possible. 

Sincerely, 

()W\ 

Debra Murie 

6654 Flamingo 

Bonanza, OR 97623 

Sent certified and regular maill/13/15 · EXHIBIT 

I 3-Z 

Case 1:15-cv-00380-CL Document 1-2 Filed 03/05/15 Page 4 of 4