5285 Meadows Road
Lake Oswego, OR 97035
(503) 607-0517
elleen@lgl-advisors.com Nordiwest Local Government
Legal Advisor
May 14, 2021
BY EMAIL
Mary Eng
Maryengl@gmail.com
Re: CEASE AND DESIST
Dear Ms. Eng:
‘As you are aware from our past communications, this office represents the Sunset Empire Park
and Recreation District (“SEPRD”). If you are represented by an attorney, please provide a copy
of this letter to that person so he or she may contact me directly.
Tam in receipt of an email from you sent today at 10:46 a.m. to Erika Marshall, who is one of
five volunteer elected board members for the District. The email was copied to the following
additional persons: cdelafield(@mereycorps.org (Ms. Marshall’s personal employer); and the
following media representatives: KHeffnert@kew.com; nerombie@oregonian.com;
kwilliams@oregonian.com; and bnakamura@oregonian.com.
In your email you reiterate various allegations and demands that you have repeatedly raised with
District staff, the District board, government agencies, and members of the local community
since 2017. As directed by this office and by the District's insurer, your original allegations of
misconduct by an off-duty District employee were promptly and thoroughly investigated at the
time you first raised them, and the results of the investigation were shared with you. Since the
original cease-and-desist letter from this office dated December 10, 2018, you have been notified
several times that neither the District nor law enforeement have been able to substantiate the
‘truth of your allegations, that the matter was closed, and that your continued efforts to seek
redress were harassing, and often slanderous and libelous.
Today's email directed to Ms. Marshall, her employer, and various news outlets, is further
evidence of harassment, this time directed specifically at one of the Distriet’s elected officials.
Ms. Marshall’s personal employment has nothing whatsoever to do with SEPRD, or the
decisions of the District board, or the conduct of its staff. Singling out any board member
personally, and locating and contacting her personal employer, is clear evidence of continuing
harassment that rises to the level of stalking. Making unsubstantiated allegations against Ms.
Marshall, her employer, and employees of SEPRD is clear evidence of libel.Mary Eng
May 14, 2021
Demand is hereby made that you, and anyone acting on your behalf, immediately cease and
desist defaming the SEPRD and harassing its board members and staff, either in person, by mail
or email, and on social media. Failure to comply will result in the District and/or any of the
persons you have targeted for harassment to report your conduct to law enforcement and seek a
stalking protective order from a court of law.
Eileen G. Eakins
Copy to: Skyler Archibald, Executive Director