In the Circuit Court of the State of Oregon For Multnomah County Coun N'br DA 24257394 STATE OF OREGON Crime Repon 20-681445 BALLOT MEASURE 11 Plaintiffi v. Iniornution oi Distrn'tt Attorney MICHAEL FOREST REINOEHJ. DOB ORSISSJISU) ORS 1661209) The above-named defendant(s) is accused by this mfommuon orthe cntnois) of COUNT 1 MURDER IN THE SECOND DEGREE WITH A FIREARM COUNT 2 UNLAWFUL USE OF A WITH A FIREARM, committed as follows: COUNT 1 MURDER 91 THE SECOND DEGREE WITII A FIREARM The said Dereudunds), MICHAEL FOREST REINOEI-IL, on or about August 29. 2020, in the County of State of Oregon, did unIawiuuy sud intentionally cause the death of Aaron Joseph Danielson, 131101th human being, wnlrary In the statutes in such cases made and provided and agents: the peace and dignity orihe Suite of Oregon. The state aiieges that during the commission oi this ieiony, the defendant used and threatened the use ofa firearm This count is a part nnhe sarnc act or lransacuou as the conduct aIIeged in the other counts of this charging insrruinent This mum is ofthe same and similar character as the conduct aIieged in the other wunls oi charging insIruiueni COUNT UNLAWFUL USE OF A WEAPON WITH A FIREARM The said MICHAEL FOREST REINOEIIL, on or about Augus| 29, 2020, in the County or Mulmomah. State of Oregon, did unlawfully attempt to use carry wuh intent to use and possess with intent to use unIawiuIiy agamsl Aamn Joseph Danreison, a dangerous and deadly weapon, contrary in the statutes in such cases made and provuied and against the peace and dignity of the State oi Oregon, The state further aIIeges that dunng the CommISSIon orthis felony, the defendant used and threatened the use firm This count is a part oi the sarne act or transaction as the conduct a11eged in the other counts or this charging irisIrurneni This count is oi the same and sinuIar character as the conduci nneged 111th other counts orthis charging instrument Daiod at Fenland, Oregon, in the county aforesaId, on SEPTEMBER 1. 2020. JACKSON 0513 114240 MIKE (084679 Disnnet Attorney Sentniy Amounl (Def~ REINOEHL) NO BAIL 35,001) Unironn Complaint AFFIKMA oncmiioh TI: norm Allomry [unity .tnninnytiy mints or It: and .s when h, 0R5 lel sot Imn he one 10>>de in (I: lurk-11m: or In <THE CIRCUIT COURT OF THE STATE OF OREGON FOR MULTNOMAH COUNTY STATE OF OREGON AFFIDAVIT FOR COUNTY OF MULTNOMAH ARREST WARRANT l, upon my oath, do hereby depose and say my name is Rico Beniga and I am a Police Detective for the City of Portland. have been a sworn police officer for the City of Portland for over twenty one years. I have been a Detective for over sixteen years and prior to my appointment to the Detective Division, I worked in uniformed patrol. have more than 1600 hours of training which has included the Oregon State Police Basic Academy, Portland Police Advanced Academy, Portland Police Detective Academy and Homicide Investigations Courses. I am currently assigned as a Homicide Detective and have worked in this capacity for over twelve years. During my experience as a Homicide investigator, have conducted, and or assisted in, more than two hundred homicide and death investigations and have become familiar in the manner they are conducted. have also prepared dozens of affidavits in support of search and arrest warrants in homicide and other criminal investigations. I am seeking an arrest warrant for Michael Forest REINOEHL (Male, White, DOB: - for the crime of Murder in the Second Degree with a Firearm as defined in Oregon Revised Statute 163.115 and Unlawful Use of a Weapon with a Firearm as defined in Oregon Revised Statute 166.220, in connection with the murder of Aaron Joseph Danielson (Male, White, DOB: -) which occurred on 8/29/20 at ARREST WARRANT . 1 approximately 2045 hours in the area of SW 3rd Avenue and SW Alder Street, City of 2 Portland, County of Multnomah, State of Oregon. 3 4 The facts and information set forth in this affidavit are based upon this affiant’s 5 personal involvement in this investigation as the lead investigator, the review of police 6 reports documented under Portland Police case #20-681445 and in conversations with 7 law enforcement and non-law enforcement personnel assisting in this investigation. 8 This affidavit does not contain all facts known to me and other investigators, instead, it 9 contains sufficient facts that I believe establish probable cause. The facts establishing 10 probable cause for the above listed offenses are as follows: 11 12 On 8/29/20 at approximately 2114 hours, I was notified by Portland Police 13 Homicide Sergeant Joseph Santos (#29573) that a homicide occurred in the area of SW 14 3rd Avenue and SW Alder Street. I know this location is located in the City of Portland, 15 County of Multnomah, State of Oregon. The initial information indicated a male had 16 been shot and was deceased at the location and the incident was related to the ongoing 17 protests. I responded along with other investigators to conduct the investigation and 18 arrived at approximately 2210 hours. 19 20 21 Sergeant Santos briefed me on the available information and, in part, I learned the following: 22 23 The shooting occurred on the west side of SW 3rd Avenue, just south of SW Alder 24 Street. Portland Police Rapid Response Team (RRT) members, who were assigned to 25 the ongoing protest activities, were several blocks away and responded to the area and 26 subsequently located the injured subject. Portland Fire Bureau Paramedics who were ARREST WARRANT - 2 1 with the RRT members provided aid, but the male was pronounced deceased at the 2 scene at approximately 2055 hours. 3 4 I personally examined the scene and observed the deceased male on the street 5 near the entrance to a parking garage located on the west side of SW 3rd Avenue. 6 Among other items at the scene, I observed the following: 7 8 1) One spent casing laying on the street located north of the deceased subject. 9 The spent casing was determined to be a Winchester brand, .380 caliber 10 casing and was documented as Placard #2. 11 12 2) A metal canister of “Bear Attack Deterrent” in the middle of SW 3rd Avenue 13 that was also north of where the deceased was located. Near the top of the 14 metal canister and below the plastic trigger housing of the spray, I observed a 15 large defect to the metal housing. The deformed metal appears consistent 16 with being struck with a bullet. The can of spray was documented as placard 17 #1. 18 19 20 3) Near the deceased was a black metal object which I recognized to be an expandable metal baton which was documented as Placard #7. 21 22 In addition, I know that Portland Police Homicide Detective Travis Law (#42652) 23 responded and assisted in the scene investigation. Detective Law subsequently told me 24 he recovered a metal fragment of a bullet from SW 3rd Avenue, near the cross walk at 25 the intersection of SW Morrison Street. I know this location is south of where the 26 deceased was located. ARREST WARRANT - 3 1 I know Portland Police Criminalist Jason Mills (#47777) responded to assist in 2 the scene investigation and submitted all of the recovered items into evidence, including 3 the following; 4 5 1) The .380 casing and bullet fragment on Property/Evidence Receipt #A000922 6 7 2) “Bear Attack Deterrent” on Property/Evidence Receipt #A000923 8 9 I was informed by Sergeant Santos that Portland Police Officer Joshua Dyk 10 (#58506) was part of the RRT squad that responded to the location and upon checking 11 on the deceased male, removed a holstered firearm from the waistband of the 12 deceased subject and surrendered it to fellow RRT member, Officer Brent Taylor 13 (#51250). I reviewed the report prepared by Officer Taylor who documents he was 14 present when medics cut off the deceased’s clothing and observed a holstered firearm 15 at the waist area. Officer Taylor wrote that Officer Dyk removed the holstered firearm 16 and handed it to him. Officer Taylor said he maintained custody of the firearm and 17 surrendered it to personnel from the Forensic Evidence Division. 18 19 I later reviewed the report by Criminalist Mills who received the firearm from 20 Officer Taylor. Criminalist Mills documents he was informed the firearm had been 21 secured by removing a bullet from the chamber. I reviewed photographs taken by 22 Criminalist Mills depicting the firearm and the ammunition contained therein. The firearm 23 was determined to be a Glock Model 17, SN#BAZD944. One Hornady 9mm Luger red 24 tip round was contained and removed from the chamber. The magazine accompanying 25 the firearm has a stated capacity of 17 rounds, but the magazine had an extension that 26 generally accommodates two additional rounds. The magazine was determined to have ARREST WARRANT - 4 total of 19 rounds contained therein. The rounds contained in the magazine were also Hornady 9mm Luger red tips. Based on my experience and training and based on the condition of the firearm and ammunition amount, affiant believes this firearm was not fired during the encounter. Multnomah County Medico-legal Death Investigator (DMI) Erin Patrick responded to the scene. I was present when DMI Patrick examined the deceased subject. DMI Patrick located a wallet in the right cargo pocket of the shorts. The wallet contained an Oregon Driver's license #9986873 in the name of Aaron Joseph Danielson (Date of Birth: 9/4/80). I compared the deceased subject with the driver's license photograph and confirmed he was Danielson. DMI Patrick also located three fully loaded 9mm magazines from the cargo pockets of Danielson's shorts. was briefed by several assisting detectives about their respective witness interviews. In part, I learned the following; Detective Meredith Hopper (#36239) interviewed a subject named Freedom Thompson (Male, White, DOB: -. Thompson said he was walking north on SW Avenue along the west sidewalk when he observed a group of individuals on the east side of the street. Thompson said he observed a white male enter the ramp area of the parking garage and peeked out before exiting and being joined by a second male. Thompson described the white male as wearing a white shirt and a backpack with a waist belt, oversized shorts, approximately 6'1" tall with medium blond colored hair. Thompson described the second subject as a possibly Hispanic male, approximately 5'10" tall and 215 pounds with short dark hair and wearing a dark shirt. Thompson both subjects approached the male who was shot (Danielson). Thompson said Danielson ARREST WARRANT 5 sprayed pepper spray and then he heard two gunshots. Thompson stated he did not see the shooter. Detective Hopper (#36239) also interviewed a subject named Timothy Ryerson (Male, White, who purported to know the deceased subject as "Jay". Ryerson said he was walking south on SW Avenue when he observed what he described as three black males in the area. Ryerson said one of the black males was the primary aggressor and stated, 'Were going to fucking kill you". Ryerson said he observed "Jay" pull out a can of mace and then heard two gunshots. Detective Hopper also interviewed a subject named Jonathan Hartley (Male, White, DOB: Hartley said he was driving south on SW 3'd Avenue when he stopped his vehicle for a subject who walked in front. Hartley described the subject as a black male, 20-30 years old, wearing a black colored hooded sweatshirt and had short dreadlocks. Hartley said the male turned to a second subject he believed was a black male wearing a white shirt and stated words similar to "Hey there's the guy". Hartley said he saw the male who was shot (Danielson) pull out a large can and spray it which was followed by two gun shots. Hartley estimated Danielson was approximately fifteen feet from the two subjects when the shots were fired. Detective Brad Clifton (#37152) interviewed a subject named Justin Dunlap (Male, White, Dunlap said he was livestreaming to his Facebook account when the shooting occurred and that he captured the incident. Dunlap said he was walking south on SW 3'd Avenue and was at SW Alder Street when his attention was drawn toward the individual who was subsequently shot (Danielson). Dunlap said two subjects were approaching Danielson when one of them said words similar to, "You ARREST WARRANT . 6 wanna go". Dunlap said he observed Danielson fire a spray bottle which was followed by two gunshots. Dunlap said one of the subjects was wearing a white shirt while the other was wearing all black clothing. Dunlap identified his Faoebook name as "Justin Dunlap". In addition to the above, I also know Portland Police Homicide Detective Shay Samora (#51733) conducted a recorded interview of a subject named Chandler Pappas (Male, White, I later reviewed the transcript of the interview and, in part, learned the following: Pappas identified the deceased individual as a friend he knew as "Jay". Pappas stated he and "Jay" had been drinking earlier in the evening and had gone to the downtown area to see what was going on. Pappas said he and "Jay" were walking on SW Avenue toward the Justice Center. Pappas said he and "Jay" turned back toward the intersection of SW Avenue and SW Alder Street and recalled seeing two subjects. Pappas said he and "Jay" were facing off with the two subjects. Pappas said he then heard two gun shots and described the shooter was the subject to his right, stating, "It was the guy on the fucking right who fired". Pappas stated the shooter was "right-handed" and recalled seeing the shooter putting his arm down when he turned to run. Pappas said he could not recall the exact clothing of the shooter, but stated, "It wasn't all black". Pappas further described the shooter by stating, "He was a white guy", subsequently adding, "And I'm fairly certain it was a white guy. I'm in shock, I don't remember. Like all that stuff". Pappas added he could not describe the second subject who was with the shooter. ARREST WARRANT 7 1 I subsequently met with Portland Police Officer Matt Miller (#31884) who is 2 assigned to the Portland Police Criminal Intelligence Unit. Officer Miller said he heard 3 the broadcast regarding the shooting and subsequently began reviewing open source 4 livestream videos on the internet. Officer Miller said he learned that a subject named 5 Justin Dunlap posted a livestream video to his Facebook account. Officer Miller said 6 the video was acquired and I was provided a thumb drive that contained the video 7 obtained from the following Facebook account URL: 8 (https://www.facebook.com/justin.dunlap.92/videos/10221132149871196). The video 9 will hereinafter be referred to as the “Dunlap Video”. 10 11 I reviewed the Dunlap video and determined the recording is twenty-one minutes 12 and twelve seconds in length. Dunlap is walking around the area while livestreaming the 13 ongoing activities. The following are the relevant times in the recording; 14 15 At approximately twelve minutes into the recording, Dunlap is at the corner of SW 16 3rd Avenue and SW Washington Street. While at the location, Subject #1, a male 17 dressed in a white shirt, light and dark colored vest with multiple pockets, dark baseball 18 style hat, dark three-quarter length pants and Subject #2, a male wearing a dark colored 19 hooded sweatshirt and dark pants, are loitering at the northeast corner of the 20 intersection. 21 22 At approximately sixteen minutes into the video, Subject #2 begins walking south 23 on SW 3rd Avenue with a white female. Subject #1 joins and all three individuals 24 continue south toward SW Alder Street. 25 26 ARREST WARRANT - 8 At approximately eighteen minutes Dunlap is standing at northeast corner of SW 1 2 3rd Avenue and SW Alder Street and his camera is oriented toward the southwest 3 corner of the intersection. The video captures audio of several males speaking loudly. 4 Based on clothing and positioning, a subject I believe to be Danielson, is standing in the 5 west most lane of traffic on SW 3rd Avenue and facing south and walking away from 6 Subject #1. Subject #1 is north of Danielson and is walking west across the lanes of 7 traffic of SW 3rd Avenue prompting vehicular traffic to stop. Male voices can be heard 8 yelling at this time. 9 As Subject #1 reaches the west most lane of traffic, Danielson turns around and 10 11 appears to walk towards Subject #1. Subject #1 then pivots and turns to his left and 12 faces Danielson in what this affiant believes is consistent with a “shooters stance”. This 13 affiant’s assessment is based on hours of personal and professional experience with 14 firearms training. Specifically, Subject #1 is facing Danielson with his feet apart and 15 squared toward Danielson. The arms of Subject #1 are not visible from the vantage 16 point of the video. Affiant believes this is consistent with Subject #1 holding both arms 17 out in front while holding a firearm with both hands. See below Exhibit 1 which is a still 18 frame capture from the Dunlap video. 19 20 // 21 22 // 23 24 // 25 26 // ARREST WARRANT - 9 EXHIBIT 1 1 2 3 4 5 6 7 Uninvolved subject on skateboard 8 9 10 11 Danielson Subject #1 12 After the first gun shot is heard, an explosion of what appears to be a gaseous 13 14 substance occurs, which is quickly followed by a second gunshot. Affiant believes the 15 gaseous substance was from the can of “Bear Attack Deterrent” that was being held by 16 Danielson and which exhibited damage consistent with being struck by a bullet. 17 Based on my review, I believe Subject #2 is standing to the right and slightly 18 19 forward of Subject #1and is obscured from the camera view. However, after the shots, 20 Subject #2 is seen immediately running to the north. Subject #1, steps back while still 21 facing Danielson with his right arm up and extended toward Danielson before turning 22 north and running off camera view. See below Exhibit 2 which is a still frame capture 23 from the Dunlap video immediately after the shots. 24 25 // 26 ARREST WARRANT - 10 EXHIBIT 2 1 2 3 4 5 6 7 8 9 10 On 8/31/20, I attended the post-mortem examination of Danielson conducted by 11 12 Oregon State Medical Examiner, Dr. Michele Stauffenberg. Dr. Stauffenberg 13 determined the cause of death to be a gunshot wound to the chest. Dr. Stauffenberg 14 described the gunshot wound entrance was at the right upper chest. Dr. Stauffenberg 15 described the wound track as being front to back and right to left. Dr. Stauffenberg 16 subsequently recovered a bullet from the left back area. Dr. Stauffenberg ruled the 17 manner of death as Homicide. 18 During the investigation I received numerous tips from community members who 19 20 were reviewing open source information from various social media platforms. The 21 information provided referenced or links to the Dunlap video. Other tips provided images 22 or videos of Subject #1 who is dressed in the same manner and who was observed 23 earlier in the evening prior to the shooting as well as at other protest activities. See 24 below Exhibits 3, 4 and 5. 25 26 // ARREST WARRANT - 11 EXHIBIT 3 1 2 3 4 5 6 7 8 9 10 11 12 The above still frame is from an open source video that was posted online which 13 14 appears to depict Subject #1 in downtown Portland earlier in the evening of 8/29/20. 15 Subject #1 is depicted reaching toward a pocket or pouch on left side of his vest. 16 Subject #1’s unique attire and positioning appear consistent with the subject depicted in 17 the Dunlap video and in surveillance video described below. 18 19 // 20 21 // 22 23 // 24 25 // 26 ARREST WARRANT - 12 1 EXHIBIT 4 EXHIBIT 5 2 3 4 5 6 7 8 9 10 The above still frames were obtained from open source videos that were posted 11 12 online. I viewed the video related to exhibit 4 and recognized the location as being in 13 Camas, Washington. Exhibit 4 depicts Subject #1 at a Camas, Washington protest. 14 Subject #1 appears in the video to be wearing the same vest and clothing that is in the 15 Dunlap video. Subject #1 also appears to have bandaging around his right arm and a 16 distinctive fist tattoo on the right side of his neck. 17 Exhibit 5 is a still frame from an interview posted by “Bloomberg Quick Take 18 19 News” on YouTube on 7/27/20. In the interview, the subject identified himself only as 20 “Michael” and says he is “48 years old”. The subject stated he had been shot in the 21 right upper arm and displayed the bandaging around the purported gunshot injury. 22 Affiant believes the still frames depict the same distinctive tattoo on the right side of his 23 neck. The tip included information indicating the subject’s possible name is “Michael 24 REINOEHL”. 25 26 // ARREST WARRANT - 13 checked the name of Michael REINOEHL in the Portland Police Bureau Regional Justice Information Network (Regjin) and located a Michael Forest REINOEHL (Male, White, DOB: The date of birth indicates he is 48 years old. I learned REINOEHL was arrested and identified by Portland Police on 7/5/20 during protest related activities and documented on PPB case #20-680889. I reviewed the report prepared by Officer Troy Fultz (#59125). I learned REINOEHL was charged possessing a loaded firearm in public, resisting arrest and interfering with a public safety officer. I also learned a Walther 9mm semi-auto handgun was seized from REINOEHL during his arrest. I also viewed an arrest photograph of REINOEHL and observed REINOEHL was wearing the same type of three-quarter length dark colored pants as in the Dunlap video, Exhibit 4, and the surveillance video to be described below. I reviewed the Oregon Department of Motor Vehicles driver's license record for Michael Forest REINOEHL (Male, White, DOB: 5/17/72) and noted that while his neck is partially covered by a mask, I did observe the top portion of a tattoo on the right side of his neck which I believe is the same tattoo depicted in the above described photographs. See below image. address on his license is listed as 2820 NE 92"6 Avenue Portland, OR 97220. I also noted license was issued on 7/27/20. ARREST WARRANT l4 1 Based upon the above information, I have probable cause to believe Subject #1 2 is Michael Forest REINOEHL (Male, White, DOB: 5/17/72). Subject #2 remains 3 unidentified. 4 5 On 9/2/20, I spoke with Clackamas County Deputy Shauna Woodward (#54571). 6 Deputy Woodward told me a coworker had seen open source postings regarding the 7 homicide and notified her because she had recently conducted a criminal investigation 8 of REINOEHL’S son (Devin) which is documented on CCSO case #20-070206. Deputy 9 Woodward stated she contacted me because she learned of information in her 10 investigation that could be relevant to this homicide investigation. Deputy Woodward 11 said that during her investigation, she obtained consent from Devin, to seize his phone 12 data which included text messages. Deputy Woodward said that among the texts was 13 the following from a contact labeled “Dad” on 8/7/20: 14 15 16 “Sell me the gun for a quarter pound of weed and $100 i’m getting tired of this shit I need a piece now” 17 18 Deputy Woodward said she arrested Devin on 8/12/20. Deputy Woodward said 19 she later went Devin’s address, located at 2820 NE 92nd Avenue, City of Portland, and 20 observed REINOEHL at the location. 21 22 During the investigation, Portland Police Detective Cory Stenzel (#45663) of the 23 Portland Police Bureau’s Digital Forensic Unit obtained video surveillance from the 24 Moda Tower, located at 601 SW 3rd Avenue. I reviewed surveillance footage from a 25 camera above the garage entry located on the east side walk of SW 3rd Avenue, just 26 south of SE Alder Street. The field of view of the camera looks north along the east ARREST WARRANT - 15 1 sidewalk of SW 3rd Avenue and captures the intersection of SW 3rd Avenue and SW 2 Alder Street. I noted the following actions of REINOEHL during my review; 3 4 5 8:44:05—REINOEHL is at the northeast corner of the intersection waiting to cross southbound on SW 3rd Avenue. 6 7 8:44:16—REINOEHL crosses SW Alder with a white female in a white t-shirt and 8 shorts. REINOEHL and the female are staring east down SW Alder Street. Subject #2 9 and another white female are following a few steps behind. 10 11 8:44:23—The female in the white t-shirt stops walking and stands against the 12 wall as REINOEHL continues. Danielson and Chandler Pappas are seen rounding the 13 corner from the east and turning south onto SW 3rd Avenue. REINOEHL looks back 14 toward Danielson and Pappas, but continues walking and begins reaching toward his 15 waist band. 16 17 18 19 20 21 22 23 24 25 26 8:44:26—REINOEHL turns into the garage entry and reaches toward his left front waist area. REINOEHL conceals himself, waits, and watches as Danielson and ARREST WARRANT - 16 1 Pappas continue walking by. Danielson and Pappas do not appear to interact or 2 communicate with anyone and continue southbound on SW 3rd Avenue. Danielson 3 appears to be holding a can in his right hand and what appears to be an expandable 4 baton in his left hand. 5 6 7 8 9 10 11 12 13 14 DANIELSON PAPPAS 15 16 8:44:33—After Danielson and Pappas walk by, REINOEHL begins to emerge 17 from garage while still reaching toward the pocket or pouch on his waistband. Subject 18 #2 looks back toward REINOEHL. Danielson and Pappas cross westbound across SW 19 3rd Avenue and REINOEHL and Subjects #2 follows them. The shooting occurs shortly 20 thereafter and is not captured on the surveillance video. 21 22 23 24 25 26 ARREST WARRANT - 17 8:44:57--After the shooting, REINOEHL is observed backing into view while in the west most lane. right arm is raised as he is facing toward Danielson. Subject #2 has already turned and is running away. REINOEHL then turns and runs north then east on SW Alder Street while appearing to manipulate the same area of his vest with his hands. Subject #2 running REINOEHL Based on the above information, I believe probable exists that, Michael Forest REINOEHL (Male, White, DOB: -, previously referred to in this affidavit as Subject committed Murder in the Second Degree with a Firearm as defined in Oregon Revised Statute 163.115 and Unlawful Use of a Weapon with a Firearm as defined in Oregon Revised Statute 166.220 in the shooting and murder of Aaron Joseph Danielson (Male, White, DOB: -) at SW 3''1 Avenue and SW Alder Street, City of Portland, County of Multnomah, State of Oregon. Therefore, I request a warrant of arrest be issued for Michael Forest REINOEHL (Male, White, DOB - for the charge of Murder in the Second Degree with a Firearm as defined in Oregon Revised Statute 163.115 and Unlawful Use of a Weapon ARREST WARRANT 18 1 with a Firearm as defined in Oregon Revised Statute 166.220. 2 3 I know from my training and experience, once a perpetrator of a crime has been 4 made aware they are the target of a criminal investigation, they and their associates or 5 family members, are likely to attempt to conceal, destroy or discard evidence. Based on 6 the foregoing, I request you authorize this warrant to be executed at any time of the day 7 or night. 8 9 I know from my training and experience that the premature disclosure of the 10 contents of this affidavit, warrant and District Attorney Information would jeopardize the 11 investigation because it would disclose information known only to law enforcement. 12 This disclosure could preclude law enforcement from confirming or verifying the 13 accuracy of information provided by witnesses and suspects and create a flight risk for 14 the defendant. Based on the foregoing, I request the contents and information 15 contained in this affidavit, warrant and District Attorney Information be sealed until 16 further ordered by the court. 17 18 Hon. Angela F. Lucero 19 4:49 PM, Sep 3, 2020 20 21 22 23 24 SUBSCRIBED AND SWORN TO before me this day of 25 26 Multnomah County Judge Hon. Angela F. Lucero ARREST WARRANT - 19 4:50 PM, Sep 3, 2020 . THE c1Rcu1T COURT 0: THE STATE or OREGON FOR MULTNOMAH coumv STAYE or OREGON. Conn M0. DA no. 242mm Plainfi", Rance Na. mamas v. MICHAEL FOREST REINDEHL MALE, WHITE, DOE Deiendim. WARRANT OF ARREST IN THE NAME or THE STAYE or OREGON Ta ANY POLICE OFFKZER IN THE SYATE or GREETING lnfurmaaun upun 17th having been |ms day 131a [mime me. charging me above-named wan me enenees Mums! .n me Second Dagvae erh a Fmealm as definefl 1n Oregon Rex/158d S|a|me 163 115 and UnlawM Use of 3 Weapon wi|h a Fneenn as eennea Oregon Remsed same 156 220 The com finds Tnax probame cause has been eslabhshefl <1 IN THE CIRCUIT COURT OF THE STATE OF OREGON 2 FOR MULTNOMAH COUNTY 3 STATE OF OREGON 4 COUNTY OF MULTNOMAH ) ) ) ADDENDUM AFFIDAVIT FOR SEARCH WARRANT 5 6 I, Travis Law, having been first duly sworn, depose and say that I am a Police Detective, 7 and I have been a peace officer in Oregon for seventeen (17) years, and have been a detective 8 since September 2017. I have successfully completed a twenty four (24) week Oregon Police 9 Corps Academy, satisfying certification through the Department of Public Safety Standards and 10 Training (DPSST), as well as a DPSST-certified fourteen (14) week Advanced Academy 11 administered by the Portland Police Bureau. I have also attended an eighty (80) hour DPSST- 12 certified Detective Academy. I have investigated or assisted in investigating homicide-related 13 crimes, and have prepared or assisted in preparing search warrant affidavits for numerous 14 homicide investigations. I am currently assigned to the Homicide Detail of the Detective 15 Division for the Portland Police Bureau; 16 17 That this affidavit is intended to provide probable cause to support the issuance of a 18 search warrant, and does not set forth all of the information obtained during the course of this 19 investigation; 20 21 That I am seeking a search warrant for the residence and curtilage located at 2820 NE 22 92nd Avenue #B, which is within the City of Portland, County of Multnomah, and State of 23 Oregon; 24 25 26 That I am assisting Detective Rico Beniga, DPSST #36906, of the Portland Police Bureau Homicide Detail with the investigation of the murder of 39-year-old AARON JOSEPH AFFIDAVIT - 1 1 IN THE CIRCUIT COURT OF THE STATE OF OREGON 2 FOR MULTNOMAH COUNTY 3 DANIELSON, who was shot and killed on August 29, 2020 near the intersection of SW 3rd 4 Avenue and SW Alder Street, within the City of Portland, County of Multnomah, and State 5 Oregon. That investigation is documented under Portland Police Bureau case number 20- 6 681445; 7 8 That I have spoken with Detective Beniga regarding his investigation of the murder of 9 AARON JOSEPH DANIELSON, and I have reviewed Detective Beniga’s affidavit in support of 10 arrest warrant for suspect MICHAEL FOREST REINOEHL, a male with a date of birth of May 11 17, 1972, which was approved by Multnomah County Circuit Court Judge Angela Lucero on 12 September 3, 2020 at 1649 hours. Subsequently, Judge Lucero issued an arrest warrant for 13 MICHAEL FOREST REINOEHL for violation of the crimes of Murder in the Second Degree 14 with a Firearm, as defined in Oregon Revised Statute 163.115, and Unlawful Use of a Weapon 15 with a Firearm, as defined in Oregon Revised Statue 166.220; 16 17 That Detective Beniga’s affidavit in support of arrest warrant for MICHAEL FOREST 18 REINOEHL is attached to this addendum affidavit and marked as Exhibit A, and is incorporated 19 herein by reference. Exhibit A provides details of the investigation to support this application for 20 a search warrant; 21 22 That from reviewing Exhibit A, I learned that Detective Beniga determined MICHAEL 23 FOREST REINOEHL’s address is listed as 2820 NE 92nd Avenue #B, within the City of 24 Portland, County of Multnomah, and State of Oregon; 25 26 That Detective Beniga has advised me that at the time of this affidavit, neither the firearm AFFIDAVIT - 2 THE CIRCUIT COURT OF THE STATE OF OREGON FOR MULTNOMAH COUNTY used by MICHAEL FOREST REINOEHL in the murder of AARON JOSEPH DANIELSON nor MICHAEL FOREST from that incident have been recovered: That during this investigarion, 1 read an official report wrirten by Sergeant Joseph Santos, #29573 ofrhe Homicide Detail, regarding his interview of NICK a male wirh a date of birth who is rhe owner of _Avenue, and I learned the following: NICK YODER stated he rents the basement of-- to MICHAEL FOREST REINOEHL and thar MICHAEL FOREST REINOEHL and his son "Deavln" have been there slnce January of 2020. NICK YODER further stated rhar the upstairs area rented i0 separaie earns; That the Courr should be advised that on September 3, 2020, ar approximately 1910 hours, Detecrive Beniga informed lne he was notified that MICHAEL FOREST REINOEHL was shot and killed by law enforcement at a residence locared in Laceyi Washington: That Officer James Townley, #49848, of the Portland Police Bureaui told me he personally observed the residence located ar -- and describes it as follows: --s a twosiory residence locaied on the east side of- between and The residence is yellowish in color with whire trim The numbers are dark in color and affixed horizontally ro rhe siding above the two cari attached garage, which is located on rhe norrh side ofrhe residence There is a manrdoor located to the righr side of the garage doors which is white in colorl The front door of rhe residence is brown in color, faces wesrnighr of stairs, on the second story of the dwelling There is a whire rneral railing leading up the stairs from rhe driveway There AFFIDAVIT 3 THE CIRCUIT COURT OF THE STATE OF OREGON FOR MULTNOMAI-I COUNTY are two mailboxes to Ihe right of the from door a! the top of the stairs; one is marked wilh Ihe letter and other marked vuth the [char allhough nellher door on Ihe from oflhe residence is individually marked. _ncompasses the groundrlevel living space of the residence. 1 know that--is located within the City of Portland, County of Multnomah, and State of Oregon: That 1 know based on my training and/or experience, persons who commit crimes such as Homicide, often attempt to conceal evidence of their involvement in such crimes. Persons who commit these types of crimes will conceal such evidence, including, weapons, clothing, cellular phones, and other trace evidence, in areas both familiar and immediately accessible such as residences and vehicles or if they are transient. upon their person and in their possessions; That 1 know based on my training and/or experience, written correspondence such as mail or letters, as well as other documents such as receipts and sales slips or other written materials are often left or kept inside possessions, and that such documentation can assist in the identification of owners, and/or other occupants of those possessions; That from my training and/or experience, 1 know that residences used by homicide suspects in addition to locations where a homicide occurs more often than not reveal evidence that can identify the perpetrator and/or victim of the homicide or the circumstances leading to and/or following the homicide. Such evidence includes hair. fibers, blood body fluids, weapons, firearms and firearm accessories, including holsters, shell casings, ammunition, fingerprints, photographs, videos, recording equipment. written material, clothing, or other biological materials or trace evidence. 1 also know from my training and experience that such AFFIDAVIT 4 THE CIRCUIT COURT OF THE STATE OF OREGON FOR MULTNOMAH COUNTY trace evidence can be transterred or transported by persons involved in such crimes on their persons or clothing and may easily be transferred from their persons and clothing to other surfaces. Further. [know that biological evidence. including blood, semen, and other bodily secretions can be collected. tested, identified, and compared to evidence at the scene of the crime using DNA analysis; That i know based on my training and/or experience, electronic devices, such as cellular phones, computers or other electronic devices, have inherent evidentiary value due to significant amount of information they contain. including information regarding the possessor of the device, the historical geographical locations of the device, and the communications belween the possessor of the device and others; That 1 know from my training and/or experience that forensic scientists with the Oregon State Police Forensics Laboratory are capable of conducting a direct comparison between recovered firearms. cartridge casings and bullets to determine ifa particular firearm was used in a shooting: That, in reviewing all the aboveslisted information and Exhibit A, I have probable cause to believe evidence of the crimes of Murder in the Second Degree with a Firemn, as defined in Oregon Revised Statule 163.115, and Unlawful Use of a Weapon wilh a Firearm. as defined in Oregon Revised Statule 166,220, will be found inside the residence, including the curtilage, located at-- within the City of Portland, County of Multnomah, and State of Oregon; AFFIDAVIT 5 THE CIRCUIT COURT OF THE STATE OF OREGON FOR MULTNOMAI-I COUNTY That I therefore ask the aboverentitled court issue a Search wanant authorizing the seizure and search of residence including the cunilngev located at -- within the City of Portland, County of Multnomnh, and State of Oregon: To search for, and seize instrumentalities and evidence of the crimes ofMurder in the Second Degree with a Firearm, as defined in Oregon Revised Statute 163.115, and Unlawful Use of a Weapon with a Firearm as defined in Oregon Revised Statute 166.2201 and to authorize the processing, testing and/or searching of this evidence by me and other Detectives with the Portland Police Bureau, and Criminalists from the Portland Police Bureau Porensic Evidence Division, and/or other Porensic investigators with the Oregon State Police Forensics Laboratory; To include: Evidence of the crimes of Murder in the Second Degree with a Firearm and Unlawful Use of a Weapon with a Firearm, including hairr fibers, blood uriner body fluids, weaponsr a .380 caliber handgun, .380 caliber ammunition shell casingsr holstersr fingerprints, photographs, written material, clothing, including a white shirt a light and dark colored vest with multiple pockets, a dark colored hat with light colored lettering on the front, dark (threerquarter length) pantsr dark sandals, a dark mask, cellular phonesr and other biological materials or trace evidence, including DNA swabs and evidence ofownership, including mail and receipts; That 1 further request specifically regarding cellular phonesr this affidavit and warrant only authorizes the seizure of those items, with any search and analysis to be conducted pending AFFIDAVIT 6 1 IN THE CIRCUIT COURT OF THE STATE OF OREGON 2 FOR MULTNOMAH COUNTY 3 further affidavits specifically authorizing the search and analysis of cellular phones; 4 5 That, based on my training and experience, I know once a suspect in a violent crime has 6 been made aware s/he is the target of a criminal investigation, attempts by the suspect, or others 7 close to the suspect, are likely to be made to conceal any incriminating evidence. Based on this, 8 I further request you authorize this warrant to be executed as soon as possible and at any time of 9 the day or night. 10 11 That I know from training and experience that premature disclosure of the contents of this 12 affidavit would jeopardize the investigation because it could release information known only to law 13 enforcement. This could allow information to be released that could otherwise be used to check the 14 accuracy of information given by witnesses and suspects; 15 16 Based on the foregoing, I request the affidavit be sealed until further ordered by the court. 17 18 19 _______________________________ Travis W. Law, Affiant Hon. Angela F. Lucero 8:18 PM, Sep 3, 2020 20 21 SUBSCRIBED AND SWORN TO before me this day of . 22 23 Judge 24 Hon. Angela F. Lucero 25 8:18 PM, Sep 3, 2020 26 AFFIDAVIT - 7 County of IN THE NAME OF THE STATE OF OREGON TO ANY PEACE OFFICER IN THE STATE OF OREGON, GREETIN You are hereby commanded to search the residence, including the curtilage located at - --wirhin the City of Portland, County of Mulrnomah, and Stare of Oregon. That residence is described as follows: --s a tworsrory residence located on the east side of-- between The residence is yellowish in color with white trim The numbers - are dark In Color and amxed horizontally to the siding above the 1on cari attached garage, which is located on the north side ofrhe residence There is a manrdoor located to the right side of the garage doors, which is whire in color. The front door of the residence is brown in color, faces west, and is at the top ora flight of stairs on the second story of the dwelling There is a whire rneral railing leading up the stairs from the driveway. There are two mailboxes to the right of the front door at the top of the stairs: one is marked with the letter-and other marked Vi 1th the letter -alihough neither door on the front of the residence is individually marked. --nnly encompasses the ground- level living space of the residence. To: Search for and seize any irem that is evidence of the Crimes of Murder in the Second Degree with a Firearms as defined in Oregon Revised Statute 163.115, and Unlawful Use ofa Weapon with a Firearmi as defined in Oregon Revised Starure 16612201 to include: SRCH WARR 1 Evidence of the crimes of Murder in the Second Degree with a Firearm, and Unlawful Use of a 2 Weapon with a Firearm, including, hair, fibers, blood, urine, body fluids, weapons, a .380 caliber 3 handgun, .380 caliber ammunition, shell casings, holsters, fingerprints, photographs, written 4 material, clothing, including a white shirt, a light and dark colored vest with multiple pockets, a 5 dark colored baseball-style hat with light colored lettering on the front, dark (three-quarter 6 length) pants, dark sandals, a dark mask, cellular phones, and other biological materials or trace 7 evidence, including DNA swabs, and evidence of ownership, including mail and receipts. 8 9 You, other Detectives with the Portland Police Bureau, Criminalists from the Portland Police 10 Bureau Forensic Evidence Division, and/or Forensic Investigators with the Oregon State Police 11 Forensics Laboratory are further authorized to process, test, and/or search for the above 12 evidence. 13 14 You are further directed to make return of this warrant to me within five (5) days after execution 15 thereof. 16 17 It is further ordered that the contents of this search warrant and affidavit be sealed until further 18 ordered by the court. This warrant may be executed at any time of the day or night. 19 20 ISSUED over my hand on __________________________ at ________ a.m. / p.m. 21 22 23 24 Signature of Magistrate Hon. Angela F. Lucero 25 8:19 PM, Sep 3, 2020 26 Title of Magistrate SRCH WARR - 2