ew ervanaeun 10 cca 12 13 14 15 16 17 18 19 20 24 22 23 24 25 IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF KLAMATH STATE OF OREGON, Case No, Plaintiff, Police No, KFO 16-42505 vs. DA Case No, 0093518 FLORENCE MARIE RALEY, Arresting Officer: Andreazzi Defendant. INFORMATION ‘The defendant is accused by this Accusatory Instrument of the offenses of: ASSAULT IN THE FIRST DEGREE COUNT 1 (163.185) Class A Felony The defendant, Florence Marie Raley, on or between October 1, 2015 and February 11, 2016, in Klamath County, Oregon, did unlawfully and intentionally cause serious physical injury to Alletha Darlene Chafton by means of a metal spoon, a dangerous weapon. The state further alleges that this act was separate and distinct from all others alleged, KIDNAPPING IN THE FIRST DEGREE COUNT 2 (163,235) Class A Felony ‘The defendant, Florence Marie Raley, on or between October 1, 2015 and February 11, 2016, in Klamath County, Oregon, did unlawfully and knowingly, without consent or legal authority, secretly confine Alletha Darlene Chafton in a place where she was not likely to be found, with the Intent to interfere ‘substantially with the personal liberty of Alletha Darlene Chafton, and with the Purpose of terrorizing Alletha Chafton, Page 1 - INFORMATION Klamath County Distt Attorney's fice ‘316 Main Street, Room 135, Klamath Falls, ON 97601 (541) 863-5147ON Ao ewoNe 11 12 13 14 15 16 17 18 19 20 24 22 23 24 25 The state further alleges that this act was separate and distinct from all others alleged, KIDNAPPING IN THE FIRST DEGREE COUNT 3 (163.235) Class A Felony The defendant, Florence Marie Raley, on or between October 1, 2015 and February 11, 2016, in Klamath County, Oregon, did unlawfully and knowingly, without consent or legal authority, secretly confine Alletha Darlene Chafton in @ place where she was not IIkely to be found, with the intent to interfere substantially with the personal liberty of Alletha Darlene Chafton, and with the purpose of causing physical Injury to Alletha Darlene Chafton, ‘The state further alleges that this act was separate and distinct from all others alleged, KIDNAPPING IN THE FIRST DEGREE COUNT 4 (163,235) Class A Felony ‘The defendant, Florence Marle Raley, on or between October 1, 2015 and February 11, 2016, in Klamath County, Oregon, did unlawfully and knowingly, without consent or legal authority, take Alletha Darlene Chafton from one place to another, with the intent to interfere substantially with the personal liberty of Alletha Darlene Chafton, and with the purpose of terrorizing Alletha Chafton, The state further alleges that this act was separate and distinct from all ‘others alleged, KIDNAPPING IN THE FIRST DEGREE COUNT 5 (163,235) Class A Felony ‘The defendant, Florence Marie Raley, on or between October 1, 2015 and February 11, 2016, In Klamath County, Oregon, did unlawfully and knowingly, without consent or legal authority, take Alletha Darlene Chafton from one place to another, with the intent to interfere substantially with the personal liberty of Alletha Darlene Chafton, and with the purpose of causing physical Injury to Alletha Darlene Chafton. Page 2 ~ INFORMATION Klamath County District Attorney's Office 346 Main Street, Room 135, Klamath Falls, OR 97601 (541) 883-5147COV aneune PRP RNR NMR BB ee ee ee aS ONFSOCSUSERESR ES ‘The state further alleges that this act was separate and distinct from all others alleged. ASSAULT IN THE SECOND DEGREE COUNT 6 (163,175) Class B Felony The defendant, Florence Marie Raley, on or between October 1, 2015 and February 11, 2016, In Klamath County, Oregon, did unlawfully and knowingly cause serious physical injury to Alletha Darlene Chafton by striking her. The state further alleges that this act was separate and distinct from all others alleged. UNLAWFUL SEXUAL PENETRATION IN THE FIRST DEGREE COUNT 7 (163.411) ‘Class A Felony ‘The defendant, Florence Marie Raley, on or between October 1, 2015 and February 11, 2016, In Klamath County, Oregon, did unlawfully and knowingly, by forcible compulsion, penetrate the vagina of Alletha Darlene Chafton, with an object to wit: the handle of a bathroom plunger and/or toilet brush. The state further alleges that this act was separate and distinct from all others alleged. \ CRIMINAL MISTREATMENT IN THE FIRST DEGREE COUNT 8 (163.205) Class C Felony The defendant, Florence Marle Raley, on or between October 1, 2015 and February 11, 2016, in Klamath County, Oregon, having assumed the care, custody, and responsibility for the supervision of Alletha Darlene Chafton a dependent person did unlawfully and knowingly cause physical injury to Aletha Darlene Chafton. ASSAULT IN THE THIRD DEGREE COUNT 9 (163,165) Class C Felony The defendant, Florence Marie Raley, on or between October 1, 2015 and February 11, 2016, in Klamath County Oregon, did unlawfully and knowingly, Page 3 ~ INFORMATION Klamath County District Attorney's office 316 Main Street, Room 135, Klamath Falls, OR 97601 (S41) 863-5147Se aVNannunn 12 13 14 15 16 17 18 19 20 21 22 23 24 25 while being aided by another person actually present, cause physical injury to Alletha Darlene Chafton, The state further alleges that this act was separate and distinct from all others alleged. TAMPERING WITH A WITNESS COUNT 10 (162.285) Class C Felony The defendant, Florence Marie Raley, on or between October 1, 2015 and February 11, 2016, in Klamath County, Oregon, did unlawfully and knowingly attempt to Induce Shannon Marie Roe a person whom the sald defendant believed might be called as a witness in an official proceeding, to offer false testimony or withhold testimony unlawfully. TAMPERING WITH PHYSICAL EVIDENCE COUNT 11 (162.295) Class A Misdemeanor The defendant, Florence Marie Raley, on or between October 1, 2015 and February 11, 2016, in Klamath County, Oregon, did unlawfully and knowingly destroy, mutilate, alter, conceal or remove physical evidence, to-wit: a wooden back scratcher and/or chairs, thus impairing its avallabillty, with the intent that it be unavailable In an official Proceeding which to the knowledge of sald defendant was about to be instituted to-wit: a police investigation and subsequent trial. All of the above-described conduct being contrary to the statutes in such cases made and provided, and against the peace and dignity of the State of Oregon. DATED: Tuesday, February 23, 2016 ROB W. PATRIDGE KLAMATH COUNTY DISTRICT ATTORNEY Michael J. Swanson, OSB #: 964380 Page 4 ~ INFORMATION Klamath County District Attorney's office 316 Main Street, Room 135, Klamath Falls, OR 97601 (541) 863-5147Se arAauoeune 12 13 14 15 16 17 18 19 20 24 22 23 24 25 IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF KLAMATH STATE OF OREGON, Case No. Plaintiff, Police No, KFO 16-42505 vs. DA Case No. 0093519 MELISSA ANN SHANHOLTZER, Arresting Officer: Andreazzi Defendant. INFORMATION ‘The defendant Is accused by thls Accusatory Instrument of the offenses of: KIDNAPPING IN THE FIRST DEGREE COUNT 1 (163.235) Class A Felony The defendant, Melissa Ann Shanholtzer, on or between October 1, 2015 and February 11, 2016, in Klamath County, Oregon, did unlawfully and knowingly, ‘without consent or legal authority, secretly confine Alletha Darlene Chafton in a place where she was not likely to be found, with the intent to interfere substantially with the personal liberty of Aletha Darlene Chafton, and with the purpose of causing physical injury to Alletha Darlene Chafton. KIDNAPPING IN THE FIRST DEGREE COUNT 2 (163.235) Class A Felony The defendant, Melissa Ann Shanholtzer, on or about October 1, 2015, in Klamath County, Oregon, did unlawfully and knowingly, without consent or legal authority, secretly confine Alletha Darlene Chafton in a place where she ‘was not likely to be found, with the intent to interfere substantially with the personal liberty of Alletha Darlene Chafton, and with the purpose of terrorizing Alletha Chafton. Page 1 - INFORMATION Ktamath County District attorney's oftice 346 Main Street, Room 135, Klamath Falls, OR'97601 (541) 869-5147KIDNAPPING IN THE FIRST DEGREE COUNT 3 (163.235) Class A Felony The defendant, Melissa Ann Shanholtzer, on or between October 1, 2015 and February 11, 2016, in Klamath County, Oregon, did unlawfully and knowingly, without consent or legal authority, take Alletha Darlene Chafton from one place to another, with the intent to interfere substantially with the personal liberty of Alletha Darlene Chafton, and with the purpose of terrorizing Alletha Chafton. KIDNAPPING IN THE FIRST DEGREE COUNT 4 (163.235) Class A Felony The defendant, Melissa Ann Shanholtzer, on or between October 1, 2015 and February 11, 2016, in Klamath County, Oregon, did unlawfully and knowingly, without consent or legal authority, take Alletha Darlene Chafton from one place to another, with the intent to interfere substantially with the personal liberty of Alletha Darlene Chafton, and with the purpose of causing physical injury to Alletha Darlene Chafton. ASSAULT IN THE SECOND DEGREE COUNT 5 (163.175) Class B Felony The defendant, Melissa Ann Shanholtzer, on or between October 1, 2015 and February 11, 2016, in Klamath County, Oregon, did unlawfully and knowingly cause serious physical injury to Alletha Darlene Chafton by beating her. ASSAULT IN THE THIRD DEGREE COUNT 6 (163.165) Class C Felony The defendant, Melissa Ann Shanholtzer, on or between October 1, 2015 and February 11, 2016, in Klamath County Oregon, did unlawfully and knowingly, while being aided by another person actually present, cause physical injury to Alletha Darlene Chafton. Page 2 - INFORMATION Klamath County District Attorney's office 346 Main Street, Room 135, Klamath Falls, OR 97601 (544) 863-5147Orn aueun 1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 All of the above-described conduct being contrary to the statutes in such cases made and provided, and against the peace and dignity of the State of Oregon. DATED: Tuesday, February 23, 2016 ROB W. PATRIDGE KLAMATH COUNTY DISTRICT ATTORNEY / i. |-—-———— Z Michael J. Swanson, OSB #: 964380 Deputy District Attorney IDENTIFIERS: W/F Ht: 5'05 Wt: 295 Halr: BLN Eyes: BRO DOB: 03/11/1991 SID #: 21591485 Address: 3937 Homedale Rd., Klamath Falls, OR 97603 By this pleading, we are requesting that you provide the State with the following information within your possession or control: (ORS 135,835) 4. The names and addresses and datas of birth ofall persons Including the defendant, who you Intend to Cal as wltnesses atthe tal, any oral statements of Such persons other than the defendant; 2, Any reports or statements of experts mada in ‘connection with the particular ease, including esults ‘of physical or mental’ examination and of scentiic tests, experiments ar comparisons, vnleh the defendant Intends to offer in evidence at the teal 3. Any books, papers, documents, photographs, oF tangibte objects which the defendant Intends to offer In evidence at the ial Please make the above Information avaiable at least 10 days prior to tia, Regardloa your discovery: ‘A. If your defendant ts chaegea with DUIL (with an Intoxilyzer) or OWS, we will Intcaduce documents felalive to the intoxtyzer or the suspension notice, ‘You can examine these documents by personally, Page 3 - INFORMATION B. Our case file s open to your personal inspection at all reasonable umes, with 24 hour notification, It Contain the relevant discovery Information and a ist Df names and addresses of witnesses, It the case is 8 trafic erime oF itraction, the State intends to call, among others, the officer who signed the citation. . Police ofcers listed as witnesses may malntain a personal notebook which might contain additional Information which Is notin our files, You can inepect these notes by contacting the officer at the police office. D. If for any reason you desire further information not available thréuah this recelpt, you should request the court to supervige the dlecovery proceeding as provided in ORS 135.845 &Ityou havea cose where auilo/ideo de lal ease request (ht the clscovary secrelary lease make your request at eset 10 doy pio to al them, Klamath County District Attorney's OMico 316 Main Street, Room 135, Klamoth Falls, OR 97601 (541) 883-51471 IN THE CIRCUIT COURT OF THE STATE OF OREGON Defendant. INFORMATION 2 FOR THE COUNTY OF KLAMATH 3 4 | STATE OF OREGON, Case No. Plaintiff, 5 Police No. KFO 16-42505 vs. 6 DA Case No. 0093520 : JOHNATHON STERLING MARTIN, Arresting Officer: Andreazzi 8 9 The defendant is accused by this Accusatory Instrument of the offenses of: 40 KIDNAPPING IN THE FIRST DEGREE 11 | COUNT 1 (163.235) 12 | lass A Felony The defendant, Johnathon Sterling Martin, on or between October 1, 2015 13 |and February 11, 2016, in Klamath County, Oregon, did untawfully and knowingly, without consent or legal authority, secretly confine Alletha Darlene 14 |Chafton in a place where she was not likely to be found, with the Intent to interfere substantially with the personal liberty of Alletha Darlene Chafton, 15 | and with the purpose of causing physical Injury to Alletha Darlene Chafton. 16 | rhe state further alleges that this act was separate and distinct from all 17 others alleged. 18 | KIDNAPPING IN THE FIRST DEGREE COUNT 2 (163.235) 19 | lass A Felony 30 |The defendant, Johnathon Sterling Martin, on or between October 1, 2015 and February 11, 2016, in Klamath County, Oregon, did unlawfully and 21 | knowingly, without consent or legal authority, secretly confine Alletha Darlene ap |haftom in a place where she was not likely to be found, with the Intent to 23 | Page 1 ~ INFORMATION 24 Klamath County Oistret Attorney's Office 316 Main Street, Room 135, Klamath Fells, OR 97601 (541) 889-5147 25ES ee vaunwn 13 14 15 16 17 18 19 20 aa 22 23 24 interfere substantially with the personal liberty of Alletha Darlene Chafton, and with the purpose of terrorizing Alletha Chafton. The state further alleges that this act was separate and distinct from all others alleged. KIDNAPPING IN THE FIRST DEGREE COUNT 3 (163,235) Class A Felony The defendant, Johnathon Sterling Martin, on or between October 1, 2015 and February 11, 2016, in Klamath County, Oregon, did unlawfully and knowingly, without consent or legal authority, take Alletha Darlene Chafton from one place to another, with the intent to interfere substantially with the personal liberty of Alletha Darlene Chafton, and with the purpose of terrorizing Alletha Chafton. The state further alleges that this act was separate and distinct from all others alleged. KIDNAPPING IN THE FIRST DEGREE COUNT 4 (163.235) Class A Felony The defendant, Johnathon Sterling Martin, on or between October 1, 2015 and February 11, 2016, in Klamath County, Oregon, did unlawfully and knowingly, without consent or legal authority, take Alletha Darlene Chafton from one place to another, with the Intent to interfere substantially with the personal liberty of Alletha Darlene Chafton, and with the purpose of causing physical injury to Alletha Darlene Chafton. The state further alleges that this act was separate and distinct from all others alleged, ASSAULT IN THE SECOND DEGREE COUNT 5 (163.175) Class B Felony The defendant, Johnathon Sterling Martin, on or between October 1, 2015 and February 11, 2016, in Klamath County, Oregon, did unlawfully and Page 2 - INFORMATION Klamath County District Attorney's Office £386 Hain Street, Room 135, Klamath Falls, OR 97601 (541) €83-5147knowingly cause serious physical injury to Alletha Darlene Chafton by breaking her arm. The state further alleges that this act was separate and distinct from all others alleged, ASSAULT IN THE THIRD DEGREE COUNT 6 (163.165) Class C Felony The defendant, Johnathon Sterling Martin, on or between October 1, 2015 and February 11, 2016, in Klamath County Oregon, did unlawfully and knowingly, while being aided by another person actually present, cause physical injury to Alletha Darlene Chafton. The state further alleges that this act was separate and distinct from all others alleged. ASSAULT IN THE FOURTH DEGREE COUNT 7 (163.160) Class A Misdemeanor ‘The defendant, Johnathon Sterling Martin, on or between October 1, 2015 and February 11, 2016, in Klamath County, Oregon, did unlawfully and recklessly cause physical injury to Alletha Darlene Chafton. The state further alleges that this act was separate and distinct from all others alleged. All of the above-described conduct being contrary to the statutes In such cases made and provided, and against the peace and dignity of the State of Oregon. DATED: Tuesday, February 23, 2016 ROB W. PATRIDGE KLAMATH COUNTY DISTRICT ATTORNEY inaod Swanson, OSB #: 96438 Page 3 ~ INFORMATION Klamath County District Attorney's Office 316 Main Street, Room 135, Klamath Falls, OR 97601 (541) 883-5147