6/17/2015 1:38:26 PM

14CV0835

IN THE CIRCUIT COURT FOR THE STATE OF OREGON

FOR THE COUNTY OF JOSEPHINE

EDWARD SNOOK,
Plaintiff,
Case: 14CV0835
vs.

DEBORAH SWAN,
Defendant.
OFFER OF PROOF
INCONSISTENT PRIOR STATEMENTS OF WITNESS ED SNOOK
The attached transcription is the first conversation in the video titled, "The US Observer Hired to
Expose Corruption in the Case of Charles Dyer is Compromised".

EXHIBIT
DEFENDANT
A1

INCONSISTENT PRIOR STATEMENTS OF WITNESS ED SNOOK

Plaintiff Snook has claimed this video as defamation.
This video is of the audio phone conversation between Ed Snook and Deborah Swan.
This conversation wasd when Defendant Deborah Swan was working with Plaintiff Ed Snook.
This was the 2nd phone call Defendant Swan had with Ed Snook, 3 weeks after Defendant Swan
had hired Ed Snook, the US Observer.
This conversation you will hear Plaintiff Ed Snook compliment Defendant about the evidence
she collected.
You will hear Ed Snook instruct Defendant Swan to send every piece of evidence that is
discussed to his lead investigator.
You will hear Plaintiff Ed Snook tell Defendant Swan he is looking forward to meeting her.
Plaintiff Snook tells Defendant Swan 18 times to make sure send to all of her evidence to his
investigator.

Dated this 18th day of June, 2015.

/s/ Deborah Swan

self represented litigant

CERTIFY AUTHENTIC
The attached evidence is a typed version of the full recorded conversation, a transcribed version
of the Youtube Video. This transcription was performed by the Defendant Deborah Swan.
The audio conversation was recorded using a cell phone recording software that is provided to
Cricket Wireless customers. This audio of this evidence has been entered into this case by the
Plaintiff in his Plaintiff's first cause of action. This is the certification that this evidence is the
authentic version of the audio recording. This evidence is being entered into this case as evidence
for the Defendant.
/s/ Deborah Kay Swan
JUNE 26, 2012
[Phone ringing]
Ed: US Observer.

Deborah: Hi, is this Ed?

Ed: Yeah.

Deborah: Hi! It's Deborah Swan. How are you?

Ed: I am good Deborah. How are you?

Deborah: I am doing all right. I was told by Chris that you

wanted me to uh- to give you a call and kind of go over, I guess,
where everybody is at right now and, I guess-

Ed: Yeah.

Deborah: And I guess you talked to him too.

Ed: Yeah, yesterday and I'd already told him where we were at, no
one's been directly paying and we concluded that, proved that
Charles is [mumbling]a non- hands investigation. We've- we've got
the people we need to talk to. And so the next step is to go
there and I think Lorne is at, about 50 hours in it.

Deborah: Okay.

Ed: And he has done a very in depth, excellent job. I- I was very
uh- impressed with his- what he's done.

Deborah: Alright, that's good enough.

Ed: He's uhm- he's got it down to uh- we need to go to and the
game plan is, him and I will put that together, I don't tell
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anyone that. It's- and that is the thing that we will get next
the people we need to get next to and- and that's where we are at
right now. We need to go do that.

Deborah: Alright. I don't want you to of course breach the

security of the case but, I do have a lot of uh- maybe things
tools that might be- could help you as leverage or some sort of
you know, bart- barter- uhm- bartering, if you want to call it or
I don't know- I don't know what the tactic you guys take, but I'm
gonna go- need to go talk to these people but if it had anything
to do with like Ken Western, the FBI agent or possibly the
Prosecutor. I'm not sure if you were able to listen to those
recordings that, those conversations that I've had with the
Prosecutor, also the Sheriff and the FBI agent, Ken Western. But
if you uhh- those might help with some sort of uhm, you know uhm,
I guess, I don't want to say, I don't know if the right word will
be uhh- threatening but, to use as maybe uhm- aa- what do you
call, to help support, you know, to get what the result that you
guys want, maybe that would help. Are you aware of those
conversations?

Ed: No, Lorne is. And that's- he needs to know all that what your
ideas are on talking to those people, that's not where were going
to get the new evidence. We- you know when we reopen Charles'
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case, we have to have new evidence or you simply, you know, most
people depend on what's already been hashed why- that's why they
stay in prison.

Deborah: Right, well this has- this is never been hashed, this is
never been brought to them directly, this is like the Federal
involvement type of, side of it, you know this would be like- and
there is someone that's comes forward and- and maybe he'll talk
to you ah- if you want me to, if I am allowed to give the number
to you. He claims that he has proof of, now this is pretty
serious, he's got proof of- of one of the main supporters that's
been the closest to the Dyer family, his name is Rick Light.
He's- he works directly with, he's been working with Charles'
situation through Janet and the FBI agent Ken Western.

Ant then

there is this person, his name's Paul. He has proof of uhm- ahRick Light receiving three different payments from the FBI,
during this whole time frame. One for 15,000 and then two for
$8,000. So he's got like-

Ed: Yes.

Deborah: He's got the proof of it, now can I connect with him you
to talk to him possibly?

Ed : You can connect him with Lorne.

Deborah: Okay.

Ed: Get all that to Lorne.

Deborah: Okay. Would that help? I mean, would that be a good

angle to go at possibly?

Ed: If the FBI paid him off it depends what they paid him for but
if there's- you know, illegal to Charles, then I will destroy him
with it.
Deborah: Alright. what- what it would that they have done,
they've hijacked the support. I mean they're the ones that have
steered the support on what's been, you know, uhm- basically what
I believe that- that's just speculating but that makes sense and
Nancy Genovese is another lady, she has been very close to the
Dyers, she's been- they're the ones that found the attorney, the
second attorney for Charles, is the same group. And the
undercover agent, Darren Wilburn is the one who found the
attorney Albert Hawk, and so when you- when you put all the- the,
you know connections together, you see the set-up, you see that
you know the attorney- the attorney didn't do anything for
Charles in the courtroom. So, did not present any of the
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evidence, didn't call witnesses, did not do any of this, I mean

all of the steps that should have exonerated him, like the DNA
evidence and the forensic investigation on the computer, all the
stuff that would have completely given the jury the reasonable
doubt that, you know, that none of this was ever brought up
during trial. So, then when you find out that, you know that Rick
has been paid off by the Fed, it's just- it's just- to me it
say's a setup. So, I am not sure what kind of angle you are gonna
go at but I guess, if you want me to, I can call the
investigator-

Ed:

Lorne- Lorne needs every bit of that.

Deborah: Alright.

Ed:

And, he needs to understand, absolutely needs to

understand that.

Deborah: Alright. And the grenade launcher I think I might have

mentioned it to you also, the Sheriff- the Sheriff and which is
really- the most powerful person in this whole situation, he is
supposed to be is the Sheriff. You know he is supposed to keep
the Feds out of this kind of situation. but uhm- he could- I
think they are trying to hold Charles liable for the second
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charge coming in against Charles on the grenade launcher again,

but the Sheriff then tells me during conversation that- that they
know Charles was unaware the the grenade launcher was stolen.
I've got him saying this, the prosecutor and the Fed, all three
of them during the same conversation tell me the same thing. So,
that might help-

Ed : Yeah, all of that- we need to get all of that too to Lorne.

And I- you know, obviously we are going to go after new evidence
as well but that some of that could be critical and some of it on
its own can get him out of there.

Deborah: I thought, I think it would, yeah. Alright, well hope,

I'm- I'm just dying to find out how you all do this that we are,
okay, I'm supposed to tell, basically, Chris wants to know, what
exactly that you have done, you are 50 hours in to it. So what
kind of con- I know to make these guys feel like that this is you
know moving, we're gonna have good results. What can I- what can
I tell them that can without- without breaching any security, you
know...

ED

We're gonna do everything. And we concluded that Charles his

innocence we've got a handful we need to talk to, so the next

step is to go there. I think Loren is about 50 hours in it. And
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he's done a very in depth excellent job I was very impressed with
his what he's done. We've got it down to witnesses we need to go
to,

and the game plan is, and I will put that together, we don't

tell anyone that, and that is a plan and how we will get to
investigate people we need get next too. And that's where we are
right now. We need to go do that.

Deborah

I don't want to breach any security of the case, but I

do have a lot of tools from these recordings to help you as far

as like bartering. I'm not sure what kind of approach you take,
but if you have to go out and talk to either FBI Ken Western, or
possibly the prosecutor, I'm not sure if you've been able to
listen to the recordings that I've made, and the conversations
and I had with a prosecutor, the FBI Agent Ken Western, but if
you need those to help... sort of... I'm not sure the right word
is to threaten

them, but to use as some sort of leverage to help

support and to get the results we need to get these charges

dropped,

I think

those conversations would be very helpful..

ED You know Lorne needs you need tell him all of that. He
absolutely needs to know all that! Tell him what all your ideas

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are, and that you recorded

talking to those people. That's not

where we're going to get the new evidence. In order to reopen the
case for Charles we have to have new evidence. Most people depend
on what is already been rehashed and that's why they stay in
prison.

Deborah well this has never been hashed out. The Federal
involvement has not been discussed yet. That side of it , and
there was someone that has come forward and maybe
he will talk to you guys.

He claims that he has proof of,

this is pretty serious but he says he has

now

the proof of one of

the main supporters that's the closest to the Dyer's family whose
name is Rick Light. He's been working with Charles situation with
Janet, and the FBI agent Ken Western. And he claims he knows
Charles from when they were in the military together, his name is
Paul, He told me he has proof of Rick Light receiving three
different payments from the FBI. One for 15,000, two for $8000
each.

Ed

tell all that to Loren..

you can give all that to Lorne.

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Deborah: Will that help?

Ed: If the FBI paid him off, well it depends what they paid him
for...

Deborah What they've done is they hijacked his support, basically

what I believe is Nancy Genovese

has been very closest to Jan

Dyer, and she is who helped find the Attorney for Charles. The
same group. And the undercover agent Darren Wilburn, is the one
who found a Albert Hoch.

And so when you put all the connections

together, this you see the setup. You see the Attorney didnt do
anything for Charles, and the
no evidence presented.

support group found him. There was

All of this evidence that could

of

exonerated him like the DNA and the forensic investigation of the
computer, all this stuff should've been given to the jury. None
of this has ever brought up during the trial.

Ed

Lorne needs every bit of that. He needs to understand

absolutely all that.

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Deborah oh and about the other weapons charge

charge for the weapon

for the state

I'm not sure if you're handling that, but

the Sheriff is the most powerful person is supposed to be the

Sheriff, and they're supposed to keep the Fed's out of

state

issues. So I think he would be liable for the second charge on

the same grenade launcher. He told me during

my conversation

that they all know that Charles did not know the grenade launcher
was stolen. The prosecutor, Sheriff and the Feds, all three know
that Charles did not know that anything was stolen. That might
help them out.

Ed

Give that conversation to Lauren. Were

obviously we're

going after new evidence as well, but that evidence on its own
could get him out of prison.

Deborah I'm just curious to know how you're going to do this.

Chris wants to know exactly what you've done, you figure 50 hours
into the case,

So what can I tell

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these guys to make them feel

like we're going to have good results? What can I tell them
without breaching any security? Um you know.

Ed

We've been through every bit of paperwork that has been

presented.

Loren

has been through all the videos and everything

you've sent to him. We've talked extensively with the mother and
the sister and everyone we can talk too without giving away what
we're doing.

Deborah
the rape

Are they talking about.they are more focused

along

violations and I am more focused on the details about

the actual state violations and the FBI involvement, and all
that. But have they gone into depth with you
Federal involvement?

about all the

The death threats and all that kind of

stuff?

Ed

You need to talk to Lorne about this because up until a

couple weeks ago I usually only go after new evidence...

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Deborah

The prosecutor is the one who did these violations

to this family and that's why we wanted to get you guys involved.
We all already know he's innocent! We already know
this to the little girl!.... Here's an example,
the FBI

came and

contacted her

and got the

he didn't do

Amy's daughter

daughter to come

in and speak to the Feds about Charles . The FBI interrogated her
and tried to force her to say or believe that Charles molested
her when she was little, and that she just doesn't remember.
Trying to get her to admit something that wasn't true. Things
like this are concerning. This shows that it looks like a setup.
There are lots of situations like that and I was wanting you guys
to look into this has anyone told you about that?

Ed

That all needs to go to Lorne. Get everything over to

Lorne, so we're not missing any information, but we've concluded

I think he gave me 27 reasons why and he's not guilty, and a
couple reasons why he could be guilty. Then we went back over the
back and forth, and we've concluded that he's innocent. But in
order to have all this other stuff is

great, there may have been

a conspiracy, but still at the end of the day we need to know the
facts. But at the end of the day, we're going to go to the heart
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of it and get new evidence as well. And claiming that these

people did these things to him is going to be very helpful to us.
But to go file a post-conviction case, we're going to get Charles
out of prison a hella a lot quicker if we have new evidence that
shows he did not do it.

Deborah So youre going after new evidence?.

Ed

In fact you need to go through all this with Lorne. He

needs to know everything you know.

Deborah

There is one other thing I want to ask you. I'm sure

you are aware of the way the judicial misconduct and there are
certain things that the government will reverse cases like when
his right has been violated Like when you find out the
prosecutor lied to the, and the judge does not hold him
accountable, and all these things could actually of exonerated
Charles, and get a

government reversal id someone as yourself.

if you can know how to go in and push this through that's why
someone like you can do that kind of standing up for Charles

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right's, like his habeas corpus has been violated, he never get a
fair trial, there's so
much..

Ed

I'd have to hear the exact examples of the

prosecutor,
exculpatory

if he withheld. if the prosecutor withheld

evidence that's

prosecutor caught lying

to get a reversal.

grounds for a reversal., the

or lied

to the jury, that's not grounds

Withholding exculpatory evidence that is.

But if you give all this to Lorne, and he can say "OK and we've
got this, and

this" but he needs all your information so we do

not miss anything.

Deborah

: Okay, well I'll do that to him, I'll do it, but

there's a- I actually wrote a complaint, the way that you are

supposed to, I just, well went to this one uhm- part of like
Oklahoma Judicial, I forget what the department it was- but it
tells you how to- like exactly how to write up these things, when
a judge violates or uhm- basically its called misdirection of the
Judge, when they allow certain things to happen in their
courtroom`and he did. The district attorney flat out lied and17

and withheld evidence and manipulated the evidence to the jury on

both trials. The first and the second trial and I've got a whole
like, each party on the Fed, all the way from the Federal
involvement to the judge's misconduct, to the prosecutor's
misconduct, I have actually wrote up these complaints, its
basically a lawsuit against each of these Public Servants, but I
never filed them, I just wrote them up and I was wondering if
[inaudible-[00:13:25]] you know, to review them like- this is
like a year ago, but they weren't- they were afraid that I was
going to make the judge and everybody angry and so they didn't
want to have that kind of, you know, angle so it was never looked
at, but can I go ahead and send that to Lorne? You think he'd be
interested in looking at it? Coz I have a-

Ed

: Absolutely

Deborah: Okay, okay.

Ed : You need to send him everything you've got, he needs to know

everything you know.

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Deborah : Alright, alright! Well I will do that in a- so uh- so

y'all need to have another payment before you go and finish this
with Charles? Is that what the holdup is right now?

Ed: The contact is 10,000.00 and we've been paid 5,000.00

Deborah : Alright, I just, I thought that everything was, for

Charles was included in the 5,000.00 but, I'm- I'm not part of
all that so, I will uhm-

Ed: I've- I have never told anybody 5,000 and and both the
contracts we had signed-

Deborah : Yeah I know.

Ed : The contract clearly states- yeah.

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Deborah: Yeah we'll get- we'll get it paid don't worry. I justI'm just- I thought that there was 5,000 for Charles and anything
extra the 5,000 was going to be, but then uh- like I said, that
that's not part of my, I wish I could pay it myself but, yeah
they're going to- it's going to be taken care of. Uhm- cuz Amy
Dyer needed to go to her sister coz she was wondering, she was
told by Lorne, the investigator, that- possibly that he might
want her to be there? Is that part of your plan or would you
rather just go on your own ... to Oklahoma?

Ed : Uhh- I'm gonna- as long as it's not- do you have some reason
why we shouldn't have Amy there?

Deborah: No! I mean I would like her to go- I would like to go

too. If y'all want me there, I can sit and wait. [laughs] I would
love to go.

Ed : Then you should- you should be there and run this by Lorne
because he's doing it...

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21

Deborah: Alright, I'll do that- then I'm gonna start planning for
it. I really want to see what y'all do. I've been trying to get
you guys involved for a long time, so I would love to be there
and if y'all need me to do anything I mean, it's completely justtell me and I'll- I'll be more than willing to do whatever plans
you come up with. I'll be more than willing to talk to whoever or
whatever you need me to do I'll do- more than willing to help.

Ed : We very likely will need you to do something and Lorne was

pretty impressed with you so, give him everything and tell him
you're willing to go there-

Deborah: Okay.

Ed : And we're ready to schedule a trip so-

Deborah : I'm excited! We'd kick this Fed's ass is what I want to
do! Okay, totally. So, very cool. I'm ready to schedule a trip
too, so let me get- let me- Chris will be calling me back her in
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about probably about half an hour, and I'll tell him that I'm
[inaudible-[00:15:56]] about all this and we'll I guess, as soon
as the money is paid we can start planning for the dates, is that
correct?

Ed : Yeah, and go ahead and call Lorne.

Deborah: I'm going to call him right now, yeah I'll do that,
right now.

Ed: Good.

Deborah: Alright, well good talking to you Ed and we'll talk

soon. Thanks for your time. Thank you.

Ed: Looking forward to meeting you.

Deborah: Thanks, me too, thank you so much. Buh bye.

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Ed: Bye bye.

CERTIFICATE OF SERVICE
On June 17, 2015, a true copy of this document has been efiled and served to
James LEuenberger at jIm@fights4rights.com.
/s/ Deborah Kay Swan

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