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Rick Reed's Sworn Criminal Complaint Against Rosemary Lehmberg

Rick Reed's Sworn Criminal Complaint Against Rosemary Lehmberg

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Published by Scott Cobb
Complaint alleges that Travis County DA Rosemary Lehmberg threatened correctional officers at the county jail in a way that amounts to third-degree felony obstruction or retaliation.
Complaint alleges that Travis County DA Rosemary Lehmberg threatened correctional officers at the county jail in a way that amounts to third-degree felony obstruction or retaliation.

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Published by: Scott Cobb on Jun 06, 2013
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08/17/2013

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 THE STATE OF TEXAS §§COUNTY OF TRAVIS § KNOW ALL PERSONS BY THESE PRESENTS:
COMPLAINT
TO THE DISTRICT ATTORNEY OF SAID COUNTY:NOW COMES the undersigned complainant and, pursuant to article 2.04 of the TexasCode of Criminal Procedure and section 132.001 of the Texas Civil Practice and Remedies Code,hereby makes the following complaint:My name is “Richard Dale Reed,” my date of birth is September 20, 1955, andmy address is 11614 Anatole Court, Austin, Texas, 78748, United States of America. Iam of sound mind and capable of making this declaration. I have good reason to believe,and do believe, that:Rosemary Lehmberg,a white female born October 31, 1949,on or about the thirteenth day of April, A.D. 2013, in the County of Travis and State of Texas, committed the third-degree felony offense of obstruction or retaliation in violationof section 36.06 of the Texas Penal Code and against the peace and dignity of the State.Count IIn particular, I have good reason to believe, and do believe, that, on or about theaforesaid date, in the aforesaid county and state, the aforesaid Rosemary Lehmberg didintentionally threaten to harm another, namely, Michelle Hooker, by an unlawful act,
i.e.
,by filing a criminal complaint that Lehmberg knew was not supported by probable causeand that would subject the aforesaid Michelle Hooker to being unlawfully arrested andincarcerated, to prevent the service of the aforesaid Michelle Hooker as a public servant,
i.e.
, as a senior corrections officer for the Travis County Sheriff’s Office, and Lehmbergcommunicated such threat by making the following utterance:Y’all better do somethin’ quick, because
 y’all
are going to be in jail,
not 
 me, if you don’t do something pretty quick.Count III further have good reason to believe, and do believe, that, on or about theaforesaid date, in the aforesaid county and state, the aforesaid Rosemary Lehmberg didintentionally threaten to harm another, namely, Michelle Hooker, by an unlawful act,
i.e.
,by filing a criminal complaint that Lehmberg knew was not supported by probable causeand that would subject the aforesaid Michelle Hooker to being unlawfully arrested andincarcerated, in retaliation for and on account of the service of the aforesaid MichelleHooker as a public servant,
i.e.
, as a senior corrections officer for the Travis County
 
 
ComplaintPage 2
 Sheriff’s Office, and Lehmberg communicated such threat by making the followingutterances:Oh, y’all are so screwed.Have y’all called Greg? Have y’all called him? You should. You reallyshould, ‘cause you know what you’re doing. Have you called Greg? Youshould. You really should.You know what? You know I’ll—I’ll remember this, probably.So this is how it feels. I’ll remember this.Count IIII further have good reason to believe, and do believe, that, on or about theaforesaid date, in the aforesaid county and state, the aforesaid Rosemary Lehmberg didintentionally threaten to harm another, namely, Toni Orton, by an unlawful act,
i.e.
, byfiling a criminal complaint that Lehmberg knew was not supported by probable cause andthat would subject the aforesaid Toni Orton to being unlawfully arrested andincarcerated, to prevent the service of the aforesaid Toni Orton as a public servant,
i.e.
, asa senior corrections officer for the Travis County Sheriff’s Office, and Lehmbergcommunicated such threat by making the following utterance:Y’all better do somethin’ quick, because
 y’all
are going to be in jail,
not 
 me, if you don’t do something pretty quick.Count IVI further have good reason to believe, and do believe, that, on or about theaforesaid date, in the aforesaid county and state, the aforesaid Rosemary Lehmberg didintentionally threaten to harm another, namely, Toni Orton, by an unlawful act,
i.e.
, byfiling a criminal complaint that Lehmberg knew was not supported by probable cause andthat would subject the aforesaid Toni Orton to being unlawfully arrested andincarcerated, in retaliation for and on account of the service of the aforesaid Toni Ortonas a public servant,
i.e.
, as a senior corrections officer for the Travis County Sheriff’sOffice, and Lehmberg communicated such threat by making the following utterances:Oh, y’all are so screwed.Have y’all called Greg? Have y’all called him? You should. You reallyshould, ‘cause you know what you’re doing. Have you called Greg? Youshould. You really should.You know what? You know I’ll—I’ll remember this, probably.So this is how it feels. I’ll remember this.Count VI further have good reason to believe, and do believe, that, on or about theaforesaid date, in the aforesaid county and state, the aforesaid Rosemary Lehmberg didintentionally threaten to harm another, namely, Layla Rendon, by an unlawful act,
i.e.
, byfiling a criminal complaint that Lehmberg knew was not supported by probable cause andthat would subject the aforesaid Layla Rendon to being unlawfully arrested and
 
 
ComplaintPage 3
 incarcerated, to prevent the service of the aforesaid Layla Rendon as a public servant,
i.e.
,as a Travis County Sheriff’s deputy, and Lehmberg communicated such threat by makingthe following utterance:Y’all better do somethin’ quick, because
 y’all
are going to be in jail,
not 
 me, if you don’t do something pretty quick.Count VII further have good reason to believe, and do believe, that, on or about theaforesaid date, in the aforesaid county and state, the aforesaid Rosemary Lehmberg didintentionally threaten to harm another, namely, Layla Rendon, by an unlawful act,
i.e.
, byfiling a criminal complaint that Lehmberg knew was not supported by probable cause andthat would subject the aforesaid Layla Rendon to being unlawfully arrested andincarcerated, in retaliation for and on account of the service of the aforesaid LaylaRendon as a public servant,
i.e.
, as a Travis County Sheriff’s deputy, and Lehmbergcommunicated such threat by making the following utterances:Oh, y’all are so screwed.Have y’all called Greg? Have y’all called him? You should. You reallyshould, ‘cause you know what you’re doing. Have you called Greg? Youshould. You really should.You know what? You know I’ll—I’ll remember this, probably.So this is how it feels. I’ll remember this.Grounds for ComplaintMy beliefs regarding the aforesaid matters are based upon facts gleaned from thefollowing records that I have obtained from the Travis County Sheriff’s Office (TCSO)and have personally examined:(1) a digital versatile disc (DVD) bearing the handwritten notation“Handheld Camcorder Video”;(2) a DVD bearing the handwritten notation “Central Booking FacilitySecurity Video”;(3) a DVD bearing the handwritten notation “Dep. Ribsam In-CarVideo”;(4) a copy of a TCSO Isolation Cell Record and/or Application of Protective Restraints Record containing handwritten notes of TCSOOfficer Michelle Hooker;(5) a copy of a TCSO Inmate Incident Report signed by TCSO Sgt.Layla Rendon; and(6) a copy of a TCSO report entitled “Documentation of VisualObservations, Including all Unusual, Pertinent, and Critical Events.”The aforesaid records indicate that on April 12, 2013, John Ribsam, a deputyemployed by the Travis County Sheriff’s Office and assigned to the Travis CountySheriff’s Highway Enforcement Unit, arrested the aforesaid Rosemary Lehmberg for the

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