8/30/2019 11:47 AM
19CR00847
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In the Circuit Court of the State of Oregon for Lane County

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THE STATE OF OREGON,
Case no. 19CR00847
Plaintiff,

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State’s Motion In Limine (re:
Monies Paid to Alleged Victim by
Defendant) and Response to
Defendant’s MOTION IN LIMINE
TO EXCLUDE DEFENDANT
TERRENCE BEAN’S
SETTLEMENT ACTIVITIES

vs.
TERRENCE PATRICK BEAN,

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Defendant.

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DA No. 039-279615

Patricia W. Perlow

Lane County District Attorney
125 E 8th Ave Rm 400
Eugene OR 97401
(541)682-4261 (541)682-3890 (Fax)

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COMES NOW the State of Oregon by and through Erik V. Hasselman, Deputy

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District Attorney for Lane County, and respectfully requests this Honorable Court allow the

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State’s Motion in Limine to allow introduction of the defendant’s payments to the alleged

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victim of $220,00.00 and to deny the defendant’s Motion in Limine to exclude the same.

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The State asks the Court to take judicial notice of the official court record in State v.

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Terrence Patrick Bean, Lane County Circuit Court case no. 20-14-23604. This motion and

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response is further supported by the attached affidavit of Detective Jeff Myers, and the

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following argument.

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Relevant Facts

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On December 3, 2014, the defendant was arraigned on an indictment in Lane County

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Circuit Court case no. 20-14-23604 alleging he committed sex offenses against the alleged

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victim, M.S.G.

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On July 2, 2015, the defendant, through his attorney Derek Ashton, filed a Motion for

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Civil Compromise, in an effort to have the case dismissed with prejudice. This Court denied
that motion in an order dated July 20, 2015.
STATE’S MOTION IN LIMINE AND RESPONSE TO DEFENDANT’S MOTION IN LIMINE

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The case was ultimately set for trial by the court on September 1, 2015. Despite
having been served with a lawful subpoena to appear and testify, M.S.G. failed to appear for
trial, and the State moved to dismiss the prosecution without prejudice. That request was
granted by the Honorable Jay A. McAlpin the same date.
The next day, on September 2, 2015, the defendant executed an agreement with
M.S.G.’s attorney to resolve all claims between them for the additional sum of $200,000.00.
To the State’s knowledge, at that time, the only connection between and claim against the
defendant from M.S.G. were the allegations regarding the defendant’s sexual activity with
M.S.G. at a time M.S.G. was fifteen years of age.
Undisputed is the fact defendant, through his attorney Derek Ashton, wired to the
alleged victim’s attorney, Lori Deveny, $20,000.00 on July 20, 2015, and $200,000.00 to the
alleged victim on September 8, 2015.

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Patricia W. Perlow

Lane County District Attorney
125 E 8th Ave Rm 400
Eugene OR 97401
(541)682-4261 (541)682-3890 (Fax)

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Legal Analysis
Under OEC Rule 402, all relevant evidence is admissible, unless prohibited by other
Oregon Evidence Code rule or by constitutional or statutory law. “OEC 401 establishes a
‘very low threshold’ for the admission of evidence; evidence is relevant so long as it
increases or decreases, even slightly, the probability of the existence of a fact that is of
consequence to the determination of the action” State v. Barone, 329 Or. 210, 237-8 (1999),
citing State v. Hampton, 317 Or. 251, 255 n. 8 (1993). The State asserts the defendant’s
actions in paying (or attempting to pay to) M.S.G. over $220,000.00 makes it more likely that
something occurred between the two justifying the defendant transferring that money to the
alleged victim. We further submit the probative value bears such significance, its weight is
not substantially outweighed by the danger of unfair prejudice, as the defendant suggests.
The defendant, apparently, has other explanations for providing that amount of money to the
alleged victim, which he suggests carries considerable weight.
The defendant relies on OEC 408 for exclusion of such evidence. The defendant’s
reliance on that statute to justify exclusion of otherwise relevant evidence is misplaced for
two reasons.
STATE’S MOTION IN LIMINE AND RESPONSE TO DEFENDANT’S MOTION IN LIMINE

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Although this appears to be an issue of first impression in our state, the matter of
applicability of Rule 408 evidence to a criminal proceeding has been considered by the
Washington Supreme Court. In State v. O’Connor, 155 Wash.2d 335 (2005), the Court, after
thoughtful analysis and comparison of circuit splits in the federal judiciary, concluded “that
ER 408 does not apply in criminal trials” Id. at 348. Notably, the language in Washington
Rules of Evidence ER 408, at the time of the O’Connor decision, was identical to the
language in the current version of Oregon Evidence Code Rule 408.

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However, even if this Court rejected such persuasive authority, the defendant cannot
rely on the protection of OEC 408 for his conduct, as OEC 408 itself provides “Subsection
(1) of this section also does not require exclusion when the evidence is offered for another
purpose, such as…proving an effort to obstruct a criminal investigation or prosecution”
ORS 40.190(2)(b) [italics added].

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Patricia W. Perlow

Lane County District Attorney
125 E 8th Ave Rm 400
Eugene OR 97401
(541)682-4261 (541)682-3890 (Fax)

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The defendant’s agreement to pay M.S.G. $20,000.00 in July 2015, weeks before the
trial was to be held, and an additional $200,000.00 the day after M.S.G. failed to appear to a
trial to testify for the State against the defendant, on the heels of the defendant’s efforts to
persuade the Court to dismiss the case six weeks earlier, establishes by a preponderance that
the defendant rewarded the alleged victim, through defendant’s attorney Mr. Ashton, with a
cash settlement agreement for M.S.G.’s non-appearance resulting in dismissal of the case.
The surrounding communications and collusion with M.S.G.’s attorney (Lori Deveny), as
outlined in the attached Affidavit of Jeff Myers, support this conclusion. The conduct clearly
implicates ORS 162.265 (Bribing a Witness), ORS 162.285 (Tampering with a Witness), and
evidences clear efforts to obstruct a criminal prosecution, implicating the exception to OEC
408.
Such efforts to interfere with witnesses have been held to be relevant and admissible.
See Barone, at 237-8 (effort by defendant to stop state witness from testifying was
admissible, as inference of consciousness of guilt on defendant’s part); United States v.
Posey, 611 F.2d 1389 (5th Cir. 1980) (attempted bribe of law enforcement officer was
“clearly admissible as evidence of guilt”).
STATE’S MOTION IN LIMINE AND RESPONSE TO DEFENDANT’S MOTION IN LIMINE

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For the foregoing reasons, the State respectfully asks this Honorable Court for a pretrial ruling allowing the admission of evidence of the defendant’s monetary payments to the
alleged victim in this matter.

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DATED August 29, 2019.

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PATRICIA W. PERLOW, District Attorney

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s/ Erik V. Hasselman
Erik V. Hasselman, OSB 945106
Deputy District Attorney
Erik.Hasselman@co.lane.or.us

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Patricia W. Perlow

Lane County District Attorney
125 E 8th Ave Rm 400
Eugene OR 97401
(541)682-4261 (541)682-3890 (Fax)

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I certify that I caused a true copy of this document to be served on Derek Ashton and
Kimberlee M. Petrie Volm, defendant’s attorneys of record, by electronic mail on August 30,
2019.
s/ Erik V. Hasselman
Erik V. Hasselman, OSB 945106
Deputy District Attorney
Erik.Hasselman@co.lane.or.us

STATE’S MOTION IN LIMINE AND RESPONSE TO DEFENDANT’S MOTION IN LIMINE

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In the Circuit Court of the State of Oregon for Lane County
THE STATE OF OREGON,

Case r1o. 19CR00847

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Plairrtiff,

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vs.

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Affidavit of Jeff Myers, Detective

TERRENCE PATRICK BEAhI,

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Defendant

DA No.

03 9-279615

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STATE OF OREGON

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County of Lane

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I, Jeff Myers, am a detective with the Portland Police Bureau (PPB), where I have been so
employed for over 19 years. Prior to that, I retired as a detective from the Tucson Police
Department (TPD) after having served there for nearly 21 years. Based upon an extensive

criminal investigation I condusted, I learned the following information pertaining to the case
at bar:

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In July 20 I 4, a juvenile, hereafter refered to as "MSG" reported to the Portland Police Bureau

from his home in Oceanside, Califomia, that lie had consensual sex with two adult males,
Terrence Bean and Kiah Lawson, in Eugene, Lane County, Oregon, in September,2013, when

he was fifteen years old. MSG afterward retained Attorney Lori Deveny to represent his
interests.

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On November 14,2014, a Lane County Grand Jury returned a True Bill against Defendants
'l'errence Bean and Kiah Lawson for three counts each of Sodomy in the Third Degree (ORS
163.385) and one count each of Sex Abuse in the Third Degree (ORS 163.415).

ATrIDAVII.

OF

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Err MyERS

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On Novcmber 19, ?A14, and November 20,2A14, respectively, I arrested Terrence Bean and

Kiah Lawson fcrr three counts each of Sodomy in the Third Degree (ORS 163.385) and one
count each of Sex Abuse in the Third Degree (ORS 163.415) pursuant to the Lane County
Grand Jury Indictments.

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On July 16,2A15, in a pre-trial hearing in Lane County Circuit Court, the Honorable Charles

M. Zennache (Lane County Circuit Court Judge) ruled against a defense motion brought by
Terrence Bean's criminal defense attomey, Derek Jon Ashton, to allow a Civil Compromise
in the sodomy and sex abuse case pending against defendant Terrence Bean. A trial date was
set for August I

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2015.

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On July 26,2A15, I traveled to Oceanside, California, at the request of the Clackamas County

Special Prosccutor, Senior Deputy District Attorney Scott Healy, to serve MSG with a
subpoena to appear

in Lane County Circuit Court on August 11,2015, after Attorney Lori

Deveny refused to accept service of the subpoena on behalf of her client MSG.

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During my atternpts to locate MSG in Oceanside, Califomia, and serve him with the Lane

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County subpoena,

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learned he had a juvenile triend named Ashley Hines who lived in the

vicinity of San Diego, California.

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On July 27, 2A15, I called Ashley Hines father, Frank Hines, on his cell phone. During the
course of an ensuing conversation, Mr. Hines said Ashley told her mother that MSG's attorney

told MSG he should not allow police to servo him a subpoena. Mr. Hines also said MSG and
his mother were in Eugene, Oregon, after taking a train there.

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On July 28, 2Q75, I received e-mails from Amtrak Detective Vanderfange confirming
Stephanie Pederson purchased tickets for MSG and his mother

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number 14 departing Los Angeles, Califomia, on July 24, 2015, and arriving in Eugene,
Oregon, on July 25,2015.

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On July 28,2015, I returned to Portland, Oregon, and, accompanied by other PPB personnel,
began to conduct a twenty-four hour a day surveillanoe in plain clothes with unmarked police

vehicles in Cottage Grove, Oregon (MSG's mother's place of residence) in an attempt to
locate and serve MSG with the subpoena to appear in Lane County Circuit Court on August
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I,2015.

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On July 30, 2015, Detcctivc Lin and I followed a BMW sedan driven by Stephanie Pederson

from MSG's mother's resident address in Cottage Grove, Oregon, to Springfield, Oregon,
where we orchestrated a traffic stop with local law enfcrrcement of Ms. Pederson's BMW
based upon numerous traffic violations we observed as we followed her from Cottage Grove,

to Springfield.

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On July 30, 2015, after the traffic stop of Ms. Pederson's BMW sedan, Detective Lin and I
met with Stephanie Pederson and her friend Krysta Jones at Elmer's Restaurant, 3350 Gateway

Street, Springfield, Oregon, where I interviewed both separately.

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Ms. Jones described her relationship with and knowledge of the whereabouts of Nicole and
MSG.

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Ms. Pederson (pronounced Pedderson) told me she was fliends with MSG's mother. Ms.
Pederson said MSG's mother attended a court date on .luly 16,2015, and afterward went to

California, to visit her son MSG on July 18, 2015,

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Ms. Pederson said MSG's mother called her on July 22,2015, and asked her to purchase

Amtrak tickets for MSG and her from Los Angeles, Califomia, to Eugene, Oregon. Ms.
AFFIDAVIT OF JEFF MYERS

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Pederson said MSG's mother asked her to purchase the Amtrak tickets because MSG's mother

didn't want her own credit card "being pinged". Ms. Pederson said MSC and his mother told
her they were avoiding service of a subpoena for MSG to testify in court in a sex abuse case.

Ms. Pederson said MSG's mother also had her rent them a car and motel room in Ms.

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Pederson's name
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with Ms. Pederson's credit card after MSG and she arrived in

Eugene,

Oregon, for the same reason Ms. Pederson purchased their Amtrak tickets.

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Ms. Pederson said MSC disabled a cell phone he was using after he arrived in Eugene,
Oregon, when he became aware police had recent contact in California with a friend of his

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named "Ashley".
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On July 30,2015, Detective Lin and I drove to Budget Rent A Car, 28801 Douglas Drive,
Eugene, Oregon, and obtained a copy of the rental agreement for a red Ford Focus, Stephanie
Pederson rented fbr MSG and his mother with the same Visa credit card she used to purchase

the Amtrak train tickets for them on July 23,2A15. The pickup date for the car rental was
listed as luly 29,2015 at 1545 hours, with a retum date and time of August 7,2015 by 1400

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hours.

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On July 31, 2015, Detective Lin and I drove to the GuestHouse International and met with
General Manager Bridgette Zarate. During the course of an ensuing conversation, Ms. Zarate

confirmed that Stephanie Pederson checked into room number 207 on July 28,2015 and
checked out on July 29, 2015. Ms. Zarate gave me a three page copy of the guest registration.

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On August 13, 2015, Judge Jay A. McAlpin granted a continuance of the criminal trial date

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frorn August I1,2015, to September 1,2015.

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On August 13, 2015, Lane County Chief Deputy District Attorney Hasselman issued a new
subpoena

for MSG to appear in Lane County Circuit Court on September

AFFIDAVIT oF JEFF MYERS

l, 2015. Mr.
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Hasselman and an investigator from his office afterward met personally with MSG and Lori
Deveny, and MSG was served with that subpoena requiring his appearance at the September

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1,2015, trial in Lane County Circuit Court.

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On September

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2A15, MSG failed

to appear pursuant to that subpoena in Lane County

Circuit Court and the criminal case against defbndants Terrence Bean and Kiah Lawson was
dismissed without prejudice by the Court.

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On August 31,2018, MSG called me on my cell phone and reported his attorney, Lori Deveny,

embezzled monies from him. I initiated a General Offense report and conducted a follow-up

investigation. Ms. Deveny was afterward the subject

of a ninety-two count criminal

indictment in Clackamas County, Oregon, in conjunction with the embezzlement of MSC's
monies and numerous other client-victims.

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On October 27,2018, MSG retained Attorneys Sean Riddell and Christine Mascal of the law

offices of Sean Riddell and Christine Mascal.

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On December 29,2018,

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rnet with Attorneys Sean Riddell and Christine Mascal at their

office, 2905 NE Broadway, and Mr. Riddell initiated a phone call between their client MSC,
Lane County Senior Prosecutor Erik Hasselman, Mr. Riddell, Ms. Mascal and me. During the
course of an ensuing conversation, MSC told Mr. Hasselman he wished to pursue prosecution

in the sex crimes case involving defendants Terrance Bean and Kiah Lawson and that

he

would be available for future court appearances.

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On January 7,2019, I met with Attorneys Sean Riddell and Christine Mascal at their office,
2905 NE Broadway, and, in their presence, called their client MSG on his cell phone. During
the course of an ensuing digitally recorded conversation, MSG described events that led him

not to appear for trial dates in August and September, 2015, involving defendant Terrence
AFFIDAVIT O}. JEFF MYERS

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Bean. MSG said, referring to his former attorney Lori Deveny, "She told me not to talk to
oertain people, she told me to go on the run at a certain point. She told me to come back out

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of the run. You know, she told me to just, I just did what my attomey told me to do..." MSG
said,

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was supposed to testifr but

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told not to testifu. So, if I did testify I was told I

wasn't supposed to get my money. So that's why I did not testify. And that's why my attomey

told rne to go on the run. And that's, exactly why I did.'MSG then described in detail how he
avoided subpoena service for the August/September, 2015 trial at the direction of his attorney

Lori Deveny to include using a "bumer" phone and cash to avoid police detection.

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After concluding the interview with MSG, still in the presence of Attorneys Sean Riddell and
Christine Mascal, I spoke with MSG's mother via cell phone. MSG's mother described events
that led her son MSG not to appear for trial dates in August and September, 2015, involving
def'endant Terrencc Bcan. MSG's mother said she wasn't allowed to use her credit card when

MSG and she fled Oceanside, California, at the direction of Lori Deveny, MSG's attomey.
MSG's mother said a friend named Stephanie Pederson purchased train tickets for MSG and
her and also rented a car for them to avoid police detection.

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2905 NE Broadway, and, called their client MSG on his cell phone. I then initiated

a

pre-text

call between MSG and Attorney Derek Ashton. During the course ofthe ensuing conversation,

Mr. Ashton told MSG, "we settled the case", asked MSG, uWhat do you want", and told MSG
to "Put what you [MSC] want in writing".

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On January 8,2019,1 met with Attorneys Sean Riddell and Christine Mascal at their oflice,

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On January 8,2019,1instructed MSG to send an email to Derek Ashton that read, "I did what

I was told to do. I want my settlement," pursuant to Mr. Ashton's request during the foregoing
pre-text call.

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On January 9,2019, I called MSG on his cell phone and instructed him to send an email to
Derek Ashton that read, "You asked me to email you. I haven't heard back. The Oregon State
Bar didn't help me. If you can't help me, I'm going to that asshole Myers to see if he can help,"
pursuant to Mr. Ashton's request during the tbregoing pre-text call.

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On January 9,?019, MSG received an email from Derek Ashton that read, "Hello Matteo,

My

client paid the full amount you demanded to settle your civil claims."

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On January 25, 2019,1 met Lane County Senior Prosecutor Erik Hasselman, Multnomah
County Senior Deputy District Attorney Brian Davidson, Defense Attorney Wayne Mackeson
and his client

Lori Deveny in the law library of the Multnomah County District Attorney's

Office, 1021 SW 4th Avenue, pursuant to a prearranged Proffer Agreement between Mr.
Davidson, Mr. Mackeson and Ms. Deveny.

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During the Proffer, Ms. Deveny described a conspiracy between Derek Ashton and her to
absent her client, MSG

for a surn of money, from subpoena service and his consequential

unavailability to testify at the pending criminal trial.

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Ms. Devcny said she was present at a Lane County hearing on July 16,2015, attended by
Defense Attorney Derek Ashton, Defendant Terry Bean and Clackamas County Special
Prosecutor Scott Healy wherein the Judge denied the defense motion to allow a Civil
Compromise. Ms. Deveny said Mr. Ashton called her several times as she drove back to

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Portland after the hearing in Eugene. Ms. Deveny said she told Mr. Ashton that her client,
MSG would avoid subpoena service for the sex crimes trial but did not have the resources to
do so on his own. Ms. Deveny said Mr. Ashton and she entered into an agreement within days

of the July 16, 2015, hearing and Mr. Ashton pmvided her with a sum of

money,

approximately $5000, for her client, MSG, to disappear.

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Ms. Deveny said she instructed her client, MSG to leave his residence in California, use

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"burner phone" and to use cash as he made his way to Oregon, to avoid police detection. Ms.

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Deveny said she later met with her client, MSG, and, with the help of an unnamed legal
assistant, hid him at an undisclosed location in the mountains outside of Portland.

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Ms. Deveny said she retained monies given to her by Mr. Ashton to cover her expenses and
her percentage for her professional services.

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Ms. Deveny said another sum was dispersed to her by Derek Ashton when her client, MSG,
failed to appear for trial in September 2015.

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On January 30, 2019, I called Attorney Wayne Mackeson at his office number and asked him

forthe cell phone numbers and email addresses his client Lori Deveny used in 2015, per

an

agreement Mr. Mackeson and she made with me on the day of her Proffer, January 25,2019,

to provide that information at a later date.

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Mr. Mackeson provided the cell phone number, 503 360 8030, he said Ms. Deveny used in
2015, and the e-mail,ledeveny@att.net, he said Ms. Deveny used in 2015.

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After providing the cell phone number and email address, Mr. Mackeson expressed his
concem about privileged communications between Ms. Deveny and clients not associated

with this case. I asked Mr. Mackeson

if

Ms. Deveny could provide me with Derek Ashton's

cell phone number she used to communicate with him in 2015, to address Mr. Mackeson's
concem about privileged communications between Ms. Deveny and clients not associated

with this case. Mr. Mackeson agreed to call Ms. Deveny and call me back.

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Attorney Wayne Mackeson called me on my cell phone and told me he spoke to his client

Lori Deverry and that she still had the phone, was charging it and he would text me later with
the cell phone number for Derek Ashton when he received it fiom Ms. Deveny.

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On January 30,2019,1 received a text message from Attomey Wayne Mackeson that read,
"Jeff, this is Wayne Mackeson. Mr. Derek Ashton's cell # 503 887 4500 work # 503 219 3818
although she said it might be the other way around.

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On February 6,2019, I drove to 2905 NE Broadway, the law offices of Attorneys Sean Riddell

and Christine Mascal who were currently representing MSG. Mr. Riddell and Ms. Mascal
requested and received Lori Deveny's MSC client file from the Oregon State Bar and offered

to let me review the file. Among MSG's client file was an executed "Confidential Settlement
Agreement, Release, and Lirnited Covenant Not to Sue" dated July 20,2015, wherein MSG
was to receive $20,000, from Terrence Bean through Mr. Bean's attorney Derek Ashton and
an executed "Confidential Settlement Agreement, Release,

Civil Compromise, and

General

Covenant Not to Sue", dated September 2,2015, wherein MSC was to receive $200,000 from

Terrence Bean through Mr. Bean's attomey Derek Ashton. Ms. Mascal provided me with
copies of both agreements.

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On February 27,2019, the Portland Tribune published an article indicating that a law office,

Bodyfelt Mount LLP, notified the Oregon State Bar through Attorney Peter Jarvis that

a

former Bodyfelt Mount LLP attomey, Deanna Wray, "participated in a plan to conceal a key

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witness on whom the prosecution was seeking to serve a subpoena in 2015,

as part

of a sodomy

and sexual abuse case then pendirrg against Terry Bean".

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On February 28,2019,I called Attomey Lisa Ludwig. Ms. Ludwig told me Bodyfelt Mount
LLP recently engaged an ethics attomey, Peter Jarvis, an employment attorney and a criminal
attorney (Ms. Ludwig) after former legal assistant Heather Coffey at Bodyfelt Mount LLP
AFFrDAvrr oF JEFF Mvens

PAGE 9

or 26

 I
2
3

4

confessed to the firm's staff that she and former attomey Deanna Wray at Bodyfelt Mount

LLP were complicit in hiding a witness in "the Bean case". Ms. Ludwig told me Heather
Coff'ey was represented by Attorney Josh Pond. Ms. Ludwig told me she would facilitate the

availability of Bodyfelt Mount LLP witness employees for me to interview.

5

6
7

I
I
10
11

12
13

t4

On March 7, 2Al9,l met Attomey Lisa Ludwig and Bodyfelt Mount LLP Paralegal Carol
Templeton at Bodyfelt Mount LLP, 319 SW Washington Street, suite 1200. During the course

of an ensuing interview Ms. Templeton told me a legal assistant at Bodyfelt Mount LLP
named Heather Coffey forwarded her a Willamette Week article about Lori Deveny on
January 16,2019, and proceeded to confess to her that she (Ms. Coffey) was "involved in the
participaticin and execution of hiding that witness" in the "Terry Bean sexual assault matter".

Ms. Templeton said Ms. Coffey told her she received either $2,500 or $5,000 for her role in
hiding the witness. Ms. Templeton said Ms. Coffey afterward spoke to Bodyfelt Mount LLP
Attomeys Kirstin Abel and Skip Winters.

15

16

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Partner, Kirstin Abel, at Bodyfelt Mount LLP,319 SW Washington Street, suite I200. During

the course of an interview, Ms. Abel told me Attorney Deanna Wray was the Managing
Partner at Bodyfelt Mount LLP until January 2018, when Ms. Abel took over that position.

Ms. Abel said Ms. Wray afterward left Bodyfelt Mount LLP and began to pursue a career in
real estate.

22

:ii Efr BN 25
6OSdY
o- oil s
J

On March 7,2019, I met with Attorney Lisa Ludwig and the Bodyfelt Mount LLP Managing

26
27

Ms. Abel said Bodyfelt Mount LLP Legal Assistant Heather Coffey approached her in her

oflice on January 16,2A19, was "extremely distraught" and toJd her, "l think I did something
really bad and

it oould have an impact on the finn." Ms. Abel

said Ms. Coffey told her

Attorney Lori Deveny got Ms. Wray involved in representing a witness in the Terry Bean case
named Dr. Strome. Ms. Abel said it was her understanding that "Lori Deveny drafted either a

declaration or an affidavit, um, that was used for Dr. Strome." Ms. Abel said Ms. Co{fey told
AFFIDAVIT OF

Jrrn

MVERS

PAGE IO OF 26

 1

2
3

4
5

6

her "Dr. Strome knew Terry Bean's preferences, um, and the preferences were tbr minors, umo
and that there was some effort to, um, try to quash the subpoena to Dr. Strome to testify in the
case, and that there was some sort

of declaration or affidavit associated with the attempt to

quash the subpoena." Ms. Abel said

it was "at;pical" for an attorney outside her practice to

draft a declaration or affidavit for an attomey in her practice representing a client like Dr.
Strome.

7
8

I
10
11

t2
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t4

l5

l6

Ms. Abel said Ms. Coffey told her Ms. Wray and she had a conversation about Lori Deveny's

client being actively pursued by police to serve him with a subpoena. Ms. Abel said Ms.
Coffey told her Ms. Deveny's clicnt was trying to "figure out how to not be served in the case",
and Ms. Coffey and Ms. Wray concluded, "who would ever find him in Pine Hollow?" Ms.

Abel said Ms. Coffey told her she accepted a check from Ms. Deveny for either $2,500 or
$5,000 and hid Ms. Deveny's client and mother in Ms. Coffey's family cabin in Pine Hollow

after Ms. Deveny's client and mother disabled the LoJack on their rental car. Ms. Abel said
Ms. Cot1by told her she helped Ms. Deveny's client and mother put their rental car in a garuge
at her family's Pine Hollow cabin and cover it with tarps so one could see the car.

t7
18
19

2A
21

Ms. Abel said she asked Ms. Coffby

if

anyone else at Bodyfelt Mount LLP was involved in

the foregoing, and Ms. Coffey replied that Ms. Wray told her not to tell any of the partners
because they wouldn't understand. Ms. Abel said Ms. Coffey told her she knew what she had

done was wrong and she knew she shouldn't have done it.

22
E
ov

EE€"8

23

sBEXH 24

On March 7,2A19,1 met with Attorney Lisa Ludwig and Bodyfelt Mount LLP Partner, Paul

3E$5s

"Skip" Winters, at Bodyfelt Mount LLP,319 SW Washington Street, suite 1200. During the

E!E'il

course of an ensuing interview, Mr. Winters told me he learned from Attorney Kirstin Abel

PEI"H: 25
E 3 "' *&

53

26
U

21

on January 16, 2019, about a conversation Ms. Abel had that morning with their legal
assistant, Heather Coffey. Mr. Winters said he met with Ms. Coffey later in the day and Ms.

Coffey told him Attomey Deanna Wray talked her into helping out a boy that was "on the
Arrtoavn" orr Jnrr Mvnns

PacEIlor26

 I

2
3

4
5

run". Mr. Winters said Ms. Coffey told him she drove the boy and his mom to her family's
cabin, helped them cover their car and was paid "somewhere between $2,500 to $5,000." Mr.
Winters said Ms. Coffey told him she knew what she had done was wrong and that she couldn't

believe that Ms. Wray "ever talked her into it". Mr. Winters said Ms. Coffey told him Ms.
Wray "specifically instructed her not to tell the rest of us"'

6
7
8

I
10

On March 7,2019, Attorney Paul "Skip" Winters provided me with the following cell phone
numbers and e-mail addresses for Deanna Wray and Heather Coffey:

Deanna Wray, dcawrayl ggT@gmaiL com, cell phone number 503 7301997

11

12

Heather Coffey, hcoffey2g@gmail.com, cell phone number 503 935 2593

13

t4
15

l6

On March 11. 2019, I called Dr, Glenn Strome on my cell phone. During the course of an
ensuing conversation, Dr. Strome confirmed that he had retained Attorney Deanna Wray to
represent

him in 2015, surrounding the Tery Bean case. Dr. Strome afterward agreed to

17

coordinate

I8

with tsodyfelt Mount LLP to release his client files to me for investigative

purposes.

19
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23

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26
27

On March 18,2019, I received an e-mail confirmation from Lane County Legal Secretary
Courtney Runkle that she served Lane County Grand Jury Subpoenas seeking phone records
associated

with Lori Deveny from AT&T and for phone records

associated

with

Derek

Ashton, Deanna Wray and Heather Coffey from Verizon per my request.

On March 21, 2Al9,l received call data infonnation from Verizon regarding Deanna Wray's

cell phone number 503 730 1997, Derek Ashton's cell phone number 503 887 4500 and
Heather Coff'ey's cell phone number 503 935 2593.

ATTIDAVIT OF JErr, MYENS

Pncr

12

av 26

 I
2

On March 23,2018 at 1654 hours, I received call data information from the ATT Mobility
Cornpliance Center regarding Lori Deveny's cell phone number 503 360 8030.

3

4
5

6
7
8

I
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13

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An analysis of the call data infonnatiorr from AT&T and Verizon by Portland Police Bureau
(PPB) Analyst Baleilevuka between cell phone numbers belonging to Lori Deveny, Deanna

Wray, Heather Coffey and Derek Ashton resulted two calls from Derek Ashton to Lori
Deveny on July, 15,2015; no calls between Lori Deveny and Derek Ashton on July 16, 2015,

on the day Lane County Judge Zennache denied the civil compromise in the Terrence Bean

criminal case; three calls between Lori Deveny and Deanna Wray on July 17,2015; thirty
seven text messages from Derek Ashton to

Lori Deveny between July 18, 2015, and July

19,

2015, the two days preceding the July 20, 2A15, when Derek Ashton Agreed to pay $20,000

to Lori Deveny fbr her client MSG; fifteen calls between Derek Ashton and Lori Deveny
between July 20, 2015, the date Derek Ashton agreed to pay $20,000 to Lori Deveny for her

client MSG and September 2,2015, the date Derek Ashton agreed to pay $200,000 to Lori
Deveny for her client MSC. Analyst Baleilevuka created a time line of the foregoing data (see
attachment).

17
18

t9
20

On March 25,2019,I met with Bodyfelt Mount LLP Receptionist Myka McConnell and she
gave me a copy of Attorney Deanna Wray's case file for client Dr. Glenn Strome including a

pink thumb drive labeled "7.14.15 Goecke Voice Mail".

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Upon analysis of Dr. Glenn Strome's client file, I found the followirrg:

23

27

In a section marked "Bills" on page STROME_310, was written, "A7/rc/2015 DLW Meet
with Bean attorney D. Ashton regarding strategy for preventing testimony by Dr. Strome. 0.90
hours Rate 250.00 Amount 225.0A" and "07/16/2015 DLW Meet with victirn attorney L.
Deveny regarding strategy for preventing testimony by Dr. Strome. 0.60 hours Rate 250.00

Amount 150,00"
AFFTDAVTT oF JErF'

MyERs

PAcE 13 or 26

 I

2

ln

a section

marked "Bills" on page STROME_00031 1, was written, "0712012A15 DLW Email

3

correspondence
4
5

6

with C. Strome regarding requests for interviews, San Francisco lawyer

recommendation, and receipt

of subpoena via mail." and on "07120/2015 DLW

Email

correspondence to D. Ashton, counsel for defendant Bean, regarding whether service by rnail
is sufficient for a criminal trial subpoena."

7
8

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ll
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13

14

I5

In a section rnarked "Bills" on page STROME_00031l, was written,"07l3712015 DLW Email
correspondence

to G. Strome regarding news article regarding victim's disappearance

and

likelihood of trial."

In a section marked "Emails" on page STROME*000229, was an e-mail from Deanna Wray
to Heather Coffey dated, January 13, 201 5, at 0929 hours, that read, "need to open a file. just
me. $250/trr. i was going to use some version of the fee agreement i sent you. his is a "witness"

of sorts in a big sex abuse scandal where lori deveny represents the 15 yr old victim."

16

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l8

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2l
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(E

In a section marked "Emails" on page STROME_000153, was an e-mail from Deanna Wray
to Glenn Strome dated, July 14,2A15, at 0854 hours, that read, "Glenn - See new version of
Declaration:" including a seven point "Declaration - C.S.' of which point four read, "l reside

in

San Francisco, California. The District Attorney's office booked my travel to Oregon

for

July 28 to July 31, but I will not come to Oregon voluntarily. My only interest in providing
any information in this matter was to be supportive of the minor victim in this specific case."

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3E:58

23

24

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26
6
27

ln a section marked "Emails" on page STROME_000143, was an e-mail from Glenn Strome
to Deanna Wray dated, January 15,2015, at 0822 hours, that read, "Only comments I would
make is regarding item 4. I might change the language to something like this: My only interest
is to providing any information in this matter was to be supportive of the minor victim in this

Aru rDAvt'r or JEnn MvEns

Pncr: 14 or 26

 I
2

specific case and to decrease the likelihood of future victims. Let me know if you think that
is a problem. Othenvise everything is accurate. Thanks, Glenn."

a

J

4
5

6
7
B

I
10

In a section marked "Emails" on page STROME_000075, was an e-mail frorn Heather Coffey
to tara.l.gtange@state.or.us and cc: Lori Deveny dated, July 16, 201 5, at 0754 hours, that read,

"Ms. Grange, Attached please find a copy of the Petition to Appoint Cuardian Ad Litem by
Lori Deveny and set to be heard this moming. Ms. Deveny had planned to arrive to court early
to provide a judicial copy, but may not be able to arrive early. Please do not hesitate to contact
me of [sic] you have any questions or concems. Thank you for you continuing courtesies. Best

regards, Heather A. Coffey Legal Assistant".

11

12

r3
14

l5

In a section marked "Emails" on page STROME_000062, was an e-mail from Deanna Wray

to Glenn Strome dated, July 16, 2015, at 1233 hours, that read, "Glenn - it was denied,
meaning the trial is still on. I
the DDA. I don't think he

will call you to discuss in a bit. DO NOT TAKE CALLS FROM

will call you directly uow tliat you are represented."

16
17

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53

6

In a section marked "Emails" on page STROME_000059, was an e-mail frorn Deanna Wray
to Glenn Strome dated, July 20,2015, at 0958 hours, that read, "Hi Glenn - I assume you are
not considering the interview... I would certainly not recommend

it

since we are trying to

avoid you testifying. I expect to hear frorn the DDA today wanting to know if you are going
to get on that flight. I

it will

will

dodge him for at least one more day

if not two or three. I don't think

occur to him to try and get you served until I have confirmed you are not coming

of

your own accord. That said, if you are home during the day (or night) don't open the door to
anyone."

25

26
27

In a section marked "Ernails" on page STROME_000033, was an e-mail from Deanna Wray
to Derek Ashton dated, July 20, 2075, at 1816 hours,with an attached State of Oregon for Dr.
Glenn Strome for a kial date in Lane County for August 11,2015, that read, "l'd like to hear
AF1'1DAVS.OF JEpF

MyERs

PeOe 15 or 26

 ll
1

2

your thoughts on whether this requires any action. I would assume not since

it

was not

properly served...."

3

4
5

6
7

I
9
10

In a section marked "Emails" on page STROME_000014, was an e-mail from Deanna Wray

to Glenn Strome dated, August 14,2015, at 1518 hours, that read, "Glenn - not sure if you
have been following all this. I heard from Lori briefly that the Lane County

DA (Not Healey)

met with her client yesterday and it "went well." I'm not sure what that means but

I'll find out.

The new trial date is Septernber 1. I think at this point the DA has given up on trying to get
your testimony admitted. Have a nice weekend, Deanna", and she attached links to articles on
the Register Guard and Oregon Live.

11

12
13

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l5

In a section marked "Emails" on page STROME_00001l, was an e-mail from Deanna Wray
to Glenn Strome dated, September l, 2015, at l614 hours, that read, " Glenn, The case was
dismissed. Please let me know

if you have any questions.

Best regards, Heather

A. Coffey

Legal Assistant", and she attached links to articles on Oregon Live and KPTV.

16

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20

2l
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On April 4,2019, Lane County Senior Prosecutor Hasselman and I met Attomey Joshua Pond

and his client Heather Coffey at Mr. Pond's offrce, 12755 SW 69th Avenue, suite 200,
Portland, Oregon, to conduct a Proff'er, prearranged between Mr. Hasselman and Mr. Pond,

of Ms. Coffey. During the course of the ensuing Proffer, Ms. Coffey said

she worked at

Bodyfelt Mount LLP as a legal secretary since 2007. Ms. Coffey said she worked for Bodyfelt

Mount LLP Attorney Deanna Wray

as her assistant

until Ms. Wray officially left the Iaw firm

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in 2018.

24
25
26
21

Ms. Coffby said Deanna Wray e-mailed her an article about Lori Deveny in January 2019,
that "discussed the Terry Bean case" and, after reading it, alerted attorneys and staff at the
Bodyf'elt Mount LLP that their firm "had some sort of involvement in that". Ms. Coffey said
Deanna Wray began to represent a potential witness in the Terry Bean case named Dr. Clenn
AFFIDAVIT oF JEFT MYERS

PAOE 16 OF 26

 I

Strome and that Ms. Wray asked her "to keep it just us"

with "no acfual other attorney's

as

2

timekeepers on the case".
3

4
5

6
7

I
I
10

Ms. Coffey said in July 2015, Ms. Wray called her into her office, told her Lori Deveny's
client did not want to testify and was trying to avoid subpoena service. Ms. Cotfey said Ms.
Wray told her Ms. Wray and her "needed to brainstorm and come up, see if we could come
up with somewhere for him to stay for a few days". Ms. Coffey said Ms. Wray's suggestion
to hide Lori Deveny's client "sounded a liille hinky" to her so she asked Ms. Wray

if it was

"ok". Ms. Coffey said Ms. Wray told her "it was fine" but "her partners probably wouldn't like

it and so we would keep it just between us."

11

t7

Ms. Coffey said Ms. Wray suggested theyhide Lori Deveny's client in Pine Hollow in Wamic,

13

Oregon, at Ms. Coffey's family-owned home. Ms. Coffey said shc eventually accepted

t4

l5

$ 1,500

from Lori Deveny after Ms. Deveny called her and told her where to meet her client and his
mother to escort them to Ms. Cofl'ey's family's home in Pine Hollow.

t6

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On

April 23,2019, the Honorable M.K. Merten, Lane County Circuit Court Judge, authorized

a search warrant for Lori Deveny's resident address,7307 SE l33rd Place,

Portland,

Multnomah County, Oregon, and for the person of Lori Deveny for seizure, search, analysis,

imaging and viewing

of "any

ourrent or possessed cellular phones associated with Lori

21

Deveny capable of containing content and saved date for text messaging and eleckonic mails".
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April 25,2A19, I served the warrant authorized by Judge Merten at 7307 SE l33rd

Place.

Ms. Deveny showed me a white iPhone with a red charging cord on a kitchen counter and

:g

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s

having not asked her any questions, told rne it was the phone that had the messages. I seized
the white iPhone referred to by Ms. Deveny and ten other cell phones.

27

Arrtonvrr

ori JEru Myens

PncE 17 or 26

 lt

I

2

On April 25, 2A19,

I

gave the eleven cell phones

I

seized from 7307 SE 133rd Place to

Detective Stenzel to process pursuant to the search warrant.

i

J

4
5

6

On May 3,2019, Detective Stenzel gave me a thumb drive with an extraction of the white
iPhone Lori Deveny previously identified as the phone containing messages and an extraction

of the white iPhone found on her bedroom loveseat.

7

I
9

On May 6,2019,1 gave the thumb drives including the extractions from the two white iPhones

to Analyst Baleilevuka for analysis.

t0

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On May 7.2019, Analyst Baleilevuka gave me a sixty-eight page hard copy of the extraction

report from the white iPhone Lori Deveny previouslty identified as the phone containing
messages including text messages between

Lori Deveny (503 360 8030) and Derek Ashton

(503 887 4500) between July 18, 2A15, and August 10, 2016. I afterward had Ms. Baleilevuka
conform the dates pursuant to the search warrant authorized by Judge Merten on April 23,
2019, and Ms. Baleilevuka provided me with a sixty-fbur page hard copy of the extraction

report fiom the white iPhone Lori Deveny previously identified as the phone containing
messages including text messages between

Lori Deveny (503 360 8030) and Derek Ashton

(503 887 4500) between July I 8, 201 5, and September 9,2A15.

20

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Upon reading the extraction report from the white iPhone Lori Deveny previously identified
as the phone containing messages including text messages between

8030) and Dcrck Ashton (503 887 4500),

I

Lori Deveny (503

360

noted that the first tcxt message between Mr.

Ashton and Ms. Deveny was on July 18, 2015, (two days after Judge Zennache denied a civil
compromise in State v. Tercence Patrick Bean, Lane County Circuit Court case no 20-1423604) was Mr. Ashton informing Ms. Devenyhe had a "proposal" he wished to discuss with

Ms. Deveny and a request to call him at 503 219 3818.

Arr. IDAVI]. Or

"IEFF

MyrnS

PacE ltt or 26

 1

On July 19,2015. Mr. Ashton wrote Ms. Deveny,

o'...1

will text you the document."

2
3

On July 19,2015, Mr. Asthon sent Ms. Deveny a "PDF'Size 90899"

4
5

6

On July 19,2015, Ms. Deveny replied to Mr. Ashton,

"ls the PDF the same

as the

email I just

saw?"

7

I
I
r0

On July 19,2A15, Mr. Ashton wrote, "Yes. Wasn't sure re your tech problems."

On July 19,2015, Ms. Deveny replied to Mr. Ashton, "So a quick read,

11

and

t2

all" economic

damages

I can't

release "any

claims". Especially without prior agreement in place. I could

release that amount andl or agree to an

offset. Will talk to my clients."

l3

l4
15

On July 30,2015, Mr. Ashton wrote Ms. Deveny, "pv. Strome convinced Healy he was
out...By the way - he said they were still working hard to find MSG". Mr. Ashton further

16

asked

l7

if Ms. Deveny

was available on "Friday" after infonning her of a hearing on that day

surrounding the Terry Bean case.

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need me to call

if you

in." Ms. Deveny wrote to Mr. Ashton later that same day, "FYL According to

the detective my client is harder to find than a criminal."

22
23
24
25

EES'T

_53

On July 31,2015, Ms. Deveny wrote Mr. Ashton, "Good luck tomorrow. Let me know

On August 3,2A15, Ms. Deveny wrote Mr. Ashton, "ls there a hearing tomorrow?" and Mr.

"Hi Lori - just

Ashton replied,

an email confenal. Healy is supposed to update the parties on

the service issue. I am going to ask a deadline for Healy to request a continuance."

26
27

On August 4, 2015, Mr. Ashton wrote Ms. Deveny, "Need to talk. Did u get the Lori
Pedderson call."
AFFIDAVIT oF JEFF

MyERS

PAcE t9

or

26

 1

2
3

4
5

on August 8,2015, Mr. Ashton wrote to Ms. Deveny, "Damn. You did a good job. when can
we talk." Ms. Deveny then wrote Mr. Ashton that same date asking fbr Senior Deputy District

Attomey Healy's cell phone number then writes, "Not for the purposes of tuming himself in,

FYI.'

6
7
8

I

On August I l, 2015, Ms. Deveny wrote to Mr. Ashton about

a

meeting scheduled with Senior

Deputy District Attorney Healy at 1600 hours, and Mr. Ashton wrote, "so can come your way
around 5

if that works". Ms. Deveny wrote Mr. Ashton back, "Don't want you two to run into

10

each other. Smells bad.

I'll text you?"

1t
12

t3

l4
I5

On August 12,2015, Mr. Ashton wrote Ms. Deveny, "No phone call from Healy. My guess
is he is doubiing efforts to find MSG." That same date, Mr. Ashton wrote Ms. Deveny, "Did
you ask him to disrniss directly? What was his answer?". to which Ms. Deveny replied,

'l

did.

I got smoke blown at me about duty to the State of Oregon."

t6

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I8
r9

On August 25,2015, Ms. Deveny wrote Mr. Ashton, "You are blond copied on an email I am

sending. Don't blow my cover." and afterward corrected "blond" to "blind". Mr. Ashton
responded that same day, "Got it."

20

2r
?$ 22
9:

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23

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24

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On August 26,2A15, Mr. Ashton wrote Ms. Deveny, "Well - then I think you should appear
in person. 3:30 pm in McAlpin's court" Let's finish these guys."

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On August 29,2415, Ms. Deveny wrote Mr. Ashton, "lf he wants people not to think the kid
is not Being [sic] paid to show up, I *have [sic] to have a difIerent narrative or it looks like
collusion."

27

Arr.rnnvrr oF J rrr Myrns

PncE 2A or 26

 1

On August 31,2A15, Ms. Deveny wrote Mr. Ashton, "And they wanted to confirm MSG won't
2

be there.

REALLY?", and Mr. Ashton replied, ',You are shitting me!!!!???"

3

4

On September 1, 2015, Mr. Ashton wrote to Ms. Deveny, "Lori, I think we have a chance to
5

wrap this up tomorrow moming. But
6
7

I
I
IO

il

I

need you to work with rne. Terry is upset about a

number of things: dating back to the revealing to Healy the $200k and the recent reports re

MSG's intent to bring a civil claim. Upset

:

talking like he want to go off the reservation.

Having said that, I believe I can rope him in. I am going to need you to restrict yourself to an
agreed statement - I

will

send it to you in the am for your review - and we

that neither you nor MSG

will

will

need assurance

issue any statements to anyone except to say something like

"we will not make any statements because we have been misquoted by the press." This is a

t2
heads up about what I want us to be able to discuss in the morning. Tomorrow could be a

r3

l4
t5
16

t7
18

I9
2A

very

good day for all us us except Healy. Can I reach you at 7:45 for a few minutes to discuss?
What number do you want me to call? D" Ms. Deveny replied to Mr. Ashton, "Send me the

draft whenever. I am planning to appear via phone so it makes the statement issue easier.
BTW I NEVER said MSG intended to bring a civil case. Healy ended up being told at The
civ comp hearing in order to attempt the agreement regardless. Wonder if Judge Z willrelease.

Cood luck with client. Mine is safely in San Diego and on track with the plan. Also,
Hasselman was talking today via email that lane county is

fully in control of the case, for what

it is worth."

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22

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6

on

September

3,2015, Ms. Devenywrote Mr. Ashton, "Are we good?", and Mr. Ashton

replied to Ms. Deveny, "Yes. I feel good about it. He wants to make sure that if MSG wants

to meet him someday that will not be a violation. He is making arangements to wire the
molley to us in time for us to wire it to you in Tuesday. Chrysty will be calling fbr the routing

info - box they can't find the last instruction. I will be following up tomorrow."

27

Arr-roevrr

oF

JErr MynRs

Pncv.2l aF 26

 I

2
3

on

septernber 4, 2015, Mr. Ashton wrote Ms. Deveny, "FYI

someone walk a copy up to you today. We are hoping for

will

- terry signed. I will

have

initial wire transfer this on - which

mean we can wire you the $ on Tuesday."

4
5

6
7

on September 8, 2015, Ms. Deveny wrote Mr. Ashton, "Money?" and Mr. Ashton replied to
Ms. Deveny the same day, "l'm told the ffansfer came in this morning. I'm not sure about the
turnaround. I will put you on an email with Debra from my firm.", and later continued, "Yes

8

I

indeed. Money in the wind coming your way now. I'm told. Is everyone feeling much better
at your house?"

IO

ll
12

On September 9, 2015, Mr. Ashton wrote Ms. Deveny, "I assume you got your dinero? Are
you in and up for coffee?".

l3
14

I5
t6

l7

On May 8,2A79,1 received an e-mail from Analyst Baleilevuka including a digital copy of
six pages of e-mails between Lori Deveny and Deanna Wray and thirty-three pages of e-mails
between Lori Deveny and Derek Ashton from the extraction report fi'om the white iPhone

Lori Deveny previously identified as the phone containing messages.

I8
19

On July 2A,2015, at 1530 hours, Deanna Wray sent an e-mail to Derek Ashton and Lori

2A

Deveny that read, "Glenn has retained an attorney in SFO who is prepared to file a motion to

2l
x

*g

if

necessary. Obviously this is an expense he would rather not incur in addition to fees

22

already spent to date.

(o

EEe=E

quash

I'll keep you both posted.".

23

e;EX$ ^

ixigs 24

On July 18, 2015, at I 147 hours, Derek Ashton sent an e-mail to Lori Deveny that read, "Hi

5k Bn zs
E()SfiY

Lori, I'm sorry about your mom. I hope she is OK now. Please take a look at this and give me

.E

o-

g;

$
_5 326

u

a call to discuss (5038874500). I have funds in hand - can be wired."

27

ATT IDAVIT oF JEFF MYHRS

Pacr 22 or

26

 I

2

On July 19, 2015, at I 106 hours, Derek Ashton sent an e-mail to Lori Deveny that read, "Hi

Lori, Here is the revised Agreement."

3

4

On July 20,2015, at 0954 hours, Derek Ashton sent an e-mail to Lori Deveny that read,

5

"Excellent. Send the executed agreement and wire transfer instructions."
6

7

On July 20,2015, at 0959 hours, Derek Ashton sent an e-mail to Lori Deveny that read, "Yes
B

- make it ATTN Kristin Belisle. Derek"

9
10

il

On July 20,2015, at 1407 hours, Derek Ashton sent an e-mail to Lori Deveny that read,
"Money coming your way."

12
13

On July 2A,2015, at 1532 hours, Derek Ashton sent an e-mail to Deanna Wray and Lori

14

Deveny that read, "Thank you."
15

16

On July 20,2A15, at 1629 hours, Derek Ashton sent an e-mail to Lori Deveny that read, "Hi
17

Lori -- So, from these docs, it looks like he needs to get a judge down there to schedule

r8
hearing. Then,

t9

if

a

no objection or motion to quash, issue an order. Then, someone has to find

and serve MSG? D"

2A
21

On July 27, 2015, at 0909 hours, Derek Ashton sent an e-mail to Deanna Wray and Lori
? 22
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.co

q'*

EEE-fi

23

FiEx$
Eg:5s

24

.ii EE

25

n

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!$
rr)

Deveny that read, "Hi Deanna - I have not heard anything re Lori's client being served. Is it

still Glenn's intent not to

appear voluntarily? Thanks Derek", in response to an e-mail sent

from Deanna Wray to Derek Ashton and Lori Deveny that read, "He knows Glenn is not
coming this week. Healey says he can get thru the 104 without him as long as he can tell the

26

court Glenn is coming up for trial. what's the update on victim being served?".
27

Arr.lnRVIT oF Jnrr Myrns

Pacr 23 or 26

 1

On May 30,2079,1 called Dr. Glenn Strome on his cell phone. During the course of an ensuing
2
3

4
5

6

conversation, Dr. Strome said he believed Attomey Lori Deveny referred him to Attorney
Deanna Wray at Bodyfelt Mount LLP, who he later retained. Dr. Strome said he contacted

Portland Police prior to retaining Ms. Wray and anticipated that he was going

to "give

testimony against Terry Bean." Dr. Strome said he retained Ms. Wray because he feared
retaliation from Mr. Bean.

7
B

I
t0

II
t2

Dr. Strome said Ms. Wray told him the victim in the Terry Bean case "could not be located"
and had declined to testifu against Mr. Bean. Dr. Strome said Ms. Wray forwarded him
Oregon news articles about the Terry Bean case and he never had any awareness Ms. Wray
had any contact with Lori Deveny. Dr. Strome confirmed it was his understanding Ms. Wray
was solely representing his interests.

13

l4

Dr. Strome said he was unaware and would not have wanted Ms. Wray to consult with Terry

15

Bean's attorney, Derek Ashton, on his behalf, because
16

it was his feeling that "Terry Bean is

uh, a sex ofTender that I would not want to, um, strengthen his defense".

t7
r8

w

Dr. Strome said he was also unaware whether Lori Deveny, Deanna Wray and Heather Coffey
were complicit in hiding the juvenile victim in the Terry Bean case. Dr. Strome said he would

2A

have "felt

2t
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22

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BES-H 23
FEsHH 24
3E$5H
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>.c
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rEF'$
q9"
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26

l.o

27

a

betrayal" had he known and "concemed that this may not be in the boy's, um, best

interest" if Ms. Deveny, Ms, Wray and Ms. Coffey were complicit in hiding the victim in the

Terry Bean case.

On June 4,2019, at 1310 hours, Lane County Senior Prosecutor Erik Hasselman received an

e-mail including an attached copy of a canceled check from Attorney Joshua Pond made
payable to "Heather Coffey" from the "Law Offices of Lori E Deveny". Mr. Hasselman

forwarded Mr. Pond's e-mail including a copy of the canceled check (in the amount of
SI500.00) to me.
AFFrDAvrr oF

JEFF

MyERs

pA(iEZ4 oF 26

 il
I

2

On June 17,2A19, the Honorable M,K. Merten, Lane County Circuit Court Judge, authorized
3

a search warrant

for Lori Deveny's Wells Fargo Bank records.

4
5

6

on June 19, 2019, I drove to wells Fargo Bank, Northwest, N. A., 1405 Lloyd center,
Portland, OR, met with Branch Manager Evgenia Kazakov and served her with the Lane

7

I
I
l0

County Search Warrant for Lori Deveny's Wells Fargo Bank records.

On July 3,2019, I called Stephanie Pederson. During the course of an ensuing conversation,

Ms. Pederson described events surrounding my interview of her on July 30, 2015. Ms.

11

Pederson said she called Attomey Lori Deverry after I interviewed her on July 30, 2015, (she
1?

thought the following day) and told Ms. Deveny about her encounter with Detective Lin and

t3
me.

t4
l5

On July 9,2019, I received an e-mail from Wells Fargo Bank including bank records for Lori

t6
Deveny's "Basic Business Checking IOLTA account number 640010991

I pursuant to a Lane

17

County search warrant dated June

17

,2A19.

r8

l9

I fbund the following in Lori Deveny's Wells Fargo Bank records:

2A
21

?

22

(U

t

ov
cC)
hc)

CI,

38$5;

o .>i^ I :g 5; $n 25

6OSdY
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one canceled check dated July 29,2015, from Law Offices

payable to "Heather Coffey" for

of Lori E Deveny, made

$ 1,500

23

PtBsS
sEE$A 24
tL (Dr s
q9q

L

2.

one canceled check dated July 8,2015, from Cosgrave Vergeer Kester LLP, made

payable to "Lori E. Deveny in Trust for MSG" for $500

26
27

3.

otle "'WT" deposit on July 20,2015, from Cosgrave Vergeer Kester LLP in the amount

of $20,000
AFF-IDAVIT OT JENT

MYERS

PAGE 25 Or 26

 I
2
3

4,

one "WT" deposit on September, 8, 2015, from Cosgrave Vergeer Kester LLP in the

amount of $200,000.

4
5

I know in 2015 Derek Ashton was working as an attorney for Cosgrave Vergeer Kester LLP,

6
7

tiW:rLog

8

Jeff

9
10

1l

SUBSCRIBED AND SWORN to before me this

Zi

Trrof

August, 2019.

t2
13

FOR
r4

l5

OFFICIALSTAMP

VAilESSA GAIL MERIE ITIIATHIS
NorARy puBuc-oREG6N

l6

GOMMISSION NO.971534
MY

l7

EXPIRES FEBRUARY

13, 202?

18
19

20

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22

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23

figsx$

24

=EHES
25
HEu$$

'$-

B 26

s

27

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oF JErr

Myrns

PncE 26 or 26