Please detach and return bottom portion with your remittance. www.orcity.org/billpay MESSAGE CENTER ACCOUNT ACTIVITY UNITS CURRENT AMOUNT Previous Read Current Read Consumption Meter # Pay Your Bill Online and Sign up to Go Paperless Thank you for signing up for Online Bill Pay. You may access your account by going to www.orcity.org and click on the 'Online Bill Pay' Button to log in and make a payment. ANNIKA ERIKSSON 12054 CHAPIN CT OREGON CITY, OR 97045 Amount Due: $2,663.38 OREGON CITY UTILITY BILLING PO BOX 3530 PORTLAND OR 97208-3530 Due Date: 8/20/2025 Account Number: 01-466348-05 014663480502663387 PO BOX 3040 OREGON CITY, OR 97045-0304 Amount Enclosed: Account Number: 01-466348-05 Service Address: 12054 CHAPIN CT Service Period: 05/31/25 To 06/30/25 Amount Due: $2,663.38 Due Date: 8/20/2025 OUR RECORDS INDICATE THIS ACCOUNT IS PAST DUE. IF PAYMENT WAS RECENTLY MADE, PLEASE CALL OUR OFFICE TO CONFIRM ITS ARRIVAL. IF THE PAST DUE AMOUNT IS NOT RECEIVED IN OUR OFFICE BY 5 P.M. ON 8/20/2025, WATER SERVICE MAY BE DISCONNECTED. 625 CENTER ST PO BOX 3040 OREGON CITY, OR 97045-0304 (503) 657-8151 SEE REVERSE FOR EXPLANATION OF SERVICES AND ADDITIONAL INFORMATION The following rate adjustments will go into effect July 1, 2025: Pavement Maintenance and Wastewater Collection are adjusted annually by 3% to account for inflation per Ordinance No. 08-1007 and Resolution No. 14-17 of City Commission. Water Treatment is adjusted by 25 cents per unit of water consumed to meet the capital needs of the system as adopted by the South Fork Water Board. Wastewater Treatment is adjusted by 4.7% to meet the capital needs of the system as adopted by the Clackamas County Board of Commissioners. Previous Balance $2,607.26 Payment - Thank you $0.00 Adjustments - Credits $0.00 Beginning Balance $2,607.26 CURRENT SERVICES AND NEW ACTIVITY FOR SERVICE PERIOD 05/31/25 TO 06/30/25 Stormwater Management $14.77 Pavement Maintenance $15.99 Public Safety Facility (Temporary) $6.50 Wastewater Collection $37.36 Wastewater Treatment (Clackamas County) $31.15 Reduced Rate Discount ($49.65) $56.12 Total Current Services and New Activity: $2,663.38 Amount Due: EXHIBIT F "Unsafe, Do Not Enter or Occupy" Building Notice fr om James Sayers, Building Official (November 1, 2024) This notice, posted at 12054 Chapin Ct. on November 1, 2024, declared the continuously occupied residence "unsafe" and uninhabitable due to the lack of water service that the City itself had terminated. This action represents an escalation of punitive measures against the residents. UNSAFE DO NOT ENTER OR OCCUPY (THIS PLACARD IS NOT A DEMOLITION ORDER} wroctue 02° Been) id, found lo be sencual, dame cag andy z Legit adr ot facilities oF OMeraiss, ws byl 2 B for Murra Neto on CONG liga Matte bh ho wil a a Pot ay J Pam ARTO a Ge rats eaten) 4 f & Year yr. : : blag? {he Bed Teg » DO NOT ENTER, EXCEPT AS SPECIFICALLYAUTHORIZED BY THIS URIS" 12054 Chapin Court, Oregon City, OR 970-: Cite vara Sayary wk: DO NOT REMOVE, ALTER, ORCOVER THIS PLACARD UNTH. : AUTHORIZED By GOVERNING AUTHORITY : : EXHIBIT G Declaration of Donald Buckhout This sworn declaration by Donald Buckhout details his personal experiences and hardships resulting from the City's termination of water service, including impacts on his health, daily life, and emotional well-being. The declaration provides first-hand testimony about the consequences of living without water for over 400 days. IN THE CIRCUIT COUR T OF THE ST A TE OF OREGON FOR THE COUNTY OF CLACKAMAS Annika Eriksson, Plaintif f; v The Bank of New Y ork Mellon, et al., Defendants; and Donald Buckhout, Proposed Intervenor Case No. 24CV21417 D E C L A R A T I O N O F D O N A L D B U C K H O U T I N S U P P O R T O F I N T E R V E N T I O N A N D T R O I, Donald Buckhout, declare under penalty of perjury under Oregon law: ● I am the Movant and have personal knowledge of the facts stated herein. I have resided at 12054 Chapin Court, Oregon City , Oregon since November 2023. ● On June 25, 2024, the City terminated water service to the property As of August 4, 2025, I have endured over 405 days without this essential service. ● On June 27, 2024, the City removed the water meter On July 10, 2024, the City placed a concrete barrier over the water supply pipe, which was later marked with “OCPW” (Oregon City Public W orks). The City left the end of the water line uncapped, rendering D E C L A R A T I O N O F D O N A L D B U C K H O U T - 1 - the entire water system, including for use with any potential alternative water sources, such as rainwater catchment, useless. ● On or about July 17, 2024, I went to City Hall to make a payment and resolve the utility account. I was told that the City was not accepting payments while the total amount of fees were being calculated. ● On July 24, 2024, Plaintif f Annika Eriksson, the homeowner , sent an email to the City of fering to pay the undisputed bill amount of $724.96. The City refused this of fer and instead demanded a total of $1,919.08 to restore service. This exchange also included a reference to threats by Code Enforcement to declare our home a dangerous building and threaten eviction due to the lack of water ● The City's internal work order (WO#: 24-000915) for the shutof f and turn-on tasks lists a "T otal Costs" of $1,194.12. This unitemized work order was combined with the past-due balance to form the total demanded by the City ● The lack of running water has caused severe health hazards and worsened my medical conditions. I suf fer from hyperthyroidism and major depression. During an illness with COVID-19 in October 2024, I was too weak to stand and was forced to crawl to reach water jugs, which was a life-threatening situation that has left me with lasting trauma. The City's actions have also led to social anxiety and an inability to maintain normal hygiene, making it extremely dif ficult to appear in public, including at court hearings. ● I have experienced significant emotional distress, including anxiety and sleep disruption, directly caused by the ongoing deprivation of water and the retaliatory actions of the City , including the posting of the "Unsafe" notice. D E C L A R A T I O N O F D O N A L D B U C K H O U T - 2 - ● On August 21, 2024, Plaintif f Annika Eriksson, the homeowner , submitted an ADA accommodation request to the City of Oregon City (Exhibit I) on her own behalf to address her disability-related financial hardship, requesting mediation, a payment plan, and a review of code enforcement actions. The City’ s responses on August 22 and August 27, 2024, from Denyse McGrif f failed to engage in an interactive process and merely redirected the request to the Utility Billing of fice, of fering no relief. The City’ s deliberate indif ference to this request perpetuated the lack of water service and caused direct harm to me as a resident of the house, exacerbating my hyperthyroidism and major depression, and causing significant emotional distress, including anxiety and sleep disruption. ● I personally witnessed the City's deliberate indif ference to my basic needs as communicated through Eriksson’ s request. The City's failure to provide relief to the request directly resulted in the continued deprivation of water , which exacerbated my medical conditions and caused me to feel a heightened sense of hopelessness, alienation, and frustration. ● The City has continued to issue utility bills for sewer , stormwater , and other char ges despite the absence of water service. This has added to my financial and emotional burden. AUTHENTICA TION OF EXHIBITS Exhibit A: The City of Oregon City W ater Service Disconnection Notice dated June 24, 2024, is a true and accurate copy of an of ficial document posted at 12054 Chapin Ct., received by Movant, authenticated under OEC 901. Exhibit B: The Google Maps Street V iew screenshots of 12054 Chapin Ct., Oregon City , OR, from August 2007 and August 2024, are true and accurate representations of the property’ s D E C L A R A T I O N O F D O N A L D B U C K H O U T - 3 - condition as viewed from the street. I personally obtained these screenshots from Google Maps, a publicly accessible source, and they accurately depict the property’ s condition during those time periods, as described in the accompanying captions. Exhibit C: The email correspondence from July–August 2024, showing Plaintif f Annika Eriksson’ s rejected payment of fer , is a true and accurate copy of emails sent and received by Plaintif f Annika Eriksson, provided to Movant, authenticated under OEC 901. Exhibit D: The City of Oregon City W ork Order (WO#: 24-000915) is a true and accurate copy of the document referenced in the email exchange from Marce Berreth, authenticated under OEC 901. Exhibit E: The City of Oregon City Utility Bill dated June 30, 2025, is a true and accurate copy of a bill I received at my residence, authenticated under OEC 901. Exhibit F: The “Unsafe, Do Not Enter or Occupy” Building Notice dated November 1, 2024, is a true and accurate copy of a notice posted at 12054 Chapin Ct., received by Movant, authenticated under OEC 901. Exhibit G: The Declaration of Donald Buckhout is this sworn declaration, admissible under OEC 603 and ORCP 79. Exhibit H: The Notice of T ort Claims Against the City of Oregon City dated July 24, 2025, is a true and accurate copy of a formal filing I submitted to the City , authenticated under OEC 901. Exhibit I: The email correspondence, including Annika Eriksson’ s ADA accommodation request dated August 21, 2024, and the City’ s responses dated August 22 and August 27, 2024, are true and accurate copies of emails sent and received by Plaintif f Annika Eriksson, provided to Movant, authenticated under OEC 901.Exhibit B: The Google Maps Street V iew screenshots of 12054 Chapin Ct., Oregon City , OR, from August 2007 and August 2024, are true and D E C L A R A T I O N O F D O N A L D B U C K H O U T - 4 - accurate representations of the property’ s condition as viewed from the street. I personally obtained these screenshots from Google Maps, a publicly accessible source, and they accurately depict the property’ s condition during those time periods, as described in the accompanying captions. Executed on August 4, 2025, in Oregon City , Oregon. Donald Buckhout D E C L A R A T I O N O F D O N A L D B U C K H O U T - 5 - EXHIBIT H This formal notice, submitted to the City of Oregon City pursuant to ORS 30.275, outlines the legal claims against the City for its actions related to water service termination, excessive fees, and retaliatory conduct. The notice details the damages sought and legal bases for the claims. NOTICE OF T OR T CLAIMS Against the City of Or egon City Pursuant to ORS 30.275 and ORS 40.355 July 24, 2025 Certified Mail City of Or egon City Of fice of the Risk Management 625 Center Street Oregon City , OR 97045 C l a i m a n t N a m e : D o n a l d B u c k h o u t C u r r e n t R e s i d e n t i a l A d d r e s s : 1 2 0 5 4 C h a p i n C o u r t , O r e g o n C i t y , O R 9 7 0 4 5 T e l e p h o n e : ( 5 0 3 ) 8 5 4 - 5 0 5 6 E m a i l : d o n e b g o o d @ g m a i l c o m O c c u p a n c y C o m m e n c e d : N o v e m b e r 2 0 2 3 R e l a t e d L i t i g a t i o n : C l a c k a m a s C o u n t y C i r c u i t C o u r t C a s e N o 2 4 C V 2 1 4 1 7 ( E r i k s s o n v T h e B a n k o f N e w Y o r k M e l l o n , e t a l ) - Q u i e t T i t l e A c t i o n ; p e n d i n g i n t e r v e n t i o n a n d j o i n d e r o f C i t y a s d e f e n d a n t SUMMAR Y OF CLAIMS AND F ACTUAL ALLEGA TION On June 24, 2024, the City of Oregon City terminated water service to my residence with only same-day notice, leaving me without access to water for over 395 days. The termination occurred despite minimal arrearages and my attempts to negotiate payment. The City subsequently escalated reinstatement fees, removed the water meter , and, on July 10, 2024, placed a concrete block over the supply pipes to obstruct restoration. On October 1, 2024, the City designated my continuously occupied home as "uninhabitable" with a "Do Not Enter" sign, forcing me to source water primitively and subjecting me to public humiliation. The stress from these actions worsened a diagnosed hyperthyroidism condition and led to dehydration when I contracted COVID-19. I have also suf fered from major depression and social isolation. The City's punitive actions appear retaliatory , coinciding with the property's involvement in quiet title litigation. The statutory notice period under ORS 30.275 is tolled due to: ● The continuing violation, as the City's refusal to restore water service constitutes an ongoing tort. ● The discovery rule, as the full scope of retaliatory conduct was revealed through recent records. ● The impact of Claimant’ s disability and compounded distress, which were exacerbated by the City’ s actions and impeded earlier filing. LEGAL BASIS Federal Claims: Due Process and Equal Protection (42 U.S.C. § 1983), Americans with Disabilities Act (ADA) T itle II & Section 504 of the Rehabilitation Act N o t i c e o f T o r t C l a i m - 1 State Claims: Oregon T ort Claims Act (ORS 30.260 et seq.), Ultra V ires Acts, W rongful Billing Practices and Denial of Essential Services Common Law Claims: Negligence, Intentional and Negligent Infliction of Emotional Distress, Invasion of Privacy , Retaliation, Nuisance, T respass, and Constructive Eviction DAMAGES AND RELIEF SOUGHT I seek relief in excess of $750,000, including: ● Diminished Property V alue: $100,000+ ● Lost W ages: $50,000 ● Medical Expenses: $10,000 - $20,000 ● Property Damage (from City-installed barriers): $3,000 ● Costs for Alternative W ater/Bathing and Inflated Fees: $10,000+ ● Non-Economic Damages: For severe emotional distress, major depression, pain and suf fering, humiliation, and loss of residential enjoyment. ● Punitive Damages: For intentional, retaliatory , and unconstitutional conduct. ● Injunctive Relief: Immediate restoration of water service, removal of all obstructions, and rescission of the "uninhabitable" designation. ● Declaratory Relief: Acknowledgment that the City’ s actions violate federal and state law ● Remedial Measures: Policies, training, and oversight to prevent recurrence. PRESER V A TION DEMAND Pursuant to ORS 40.355 to avoid sanctions the City is formally requested to preserve all records related to: ● Utility billing, payment, termination, and reinstatement communications. ● Code enforcement actions, including water meter removal and habitability designation. ● Internal communications pertaining to the property or its related litigation. ● ADA accommodation requests and internal deliberations. ● Lien imposition, code enforcement, and habitability notices. ● Policies and procedures for utility shutof fs and ADA compliance. ● All records related to Clackamas County Case No. 24CV21417. ● Communications with legal counsel regarding utility service. ● Insurance communications and coverage documentation. ● Building inspection records, public health assessments, and habitability determinations. S u b m i t t e d J u l y 2 4 , 2 0 2 5 , D o n a l d B u c k h o u t 1 2 0 5 4 C h a p i n C o u r t , O r e g o n C i t y , O R 9 7 0 4 5 T e l : ( 5 0 3 ) 8 5 4 - 5 0 5 6 | E m a i l : d o n e b g o o d @ g m a i l c o m N o t i c e o f T o r t C l a i m - 2 EXHIBIT I ADA accommodation r equest email fr om Annika Eriksson to City officials (August 21, 2024) and r esponses fr om Denyse McGriff (August 22 and August 27, 2024) This email correspondence documents Annika Eriksson's formal request for ADA accommodations related to the water service disconnection and the City's failure to engage in the interactive process required by law The City's dismissive responses demonstrate deliberate indif ference to disability-related needs. The billing office is working with you. I do have any duties or authority related to your concerns. Sorry -----Original Message----- From: Anni Eriksson Sent: Monday, August 26, 2024 4 : 08 PM To: Denyse McGriff Subject: Re: Recent Code Enforcement Actions at 12054 Chapin Ct. CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. What do you mean ? Sent from my iPhone On Aug 22, 2024, at 3 : 15 PM, Denyse McGriff wrote: Thank you for your email. Your concerns are being addressed by the Utility Billing office. -----Original Message----- From: Anni Eriksson Sent: Wednesday, August 21, 2024 2 : 13 PM To: Shaunna Kaufmann Cc: go2danderson@gmail.com; jeanbob06@comcast.net; Wyatt Parno ; Adam Marl ; Mike Mitchell ; Frank O'Donnell ; Rocky Smith, Jr. ; Ryan Kersey ; Jarrod Lyman ; Hannah Schmidt ; Melissa Goss ; Brandy Houseworth ; Jennifer Piasky ; Matt Zook ; Marce Berreth ; Jennifer Cnossen ; Ashley Fraijo ; John Oreskovich ; Denyse McGriff ; Wanda Shell ; Pioneer Community Center Subject: Recent Code Enforcement Actions at 12054 Chapin Ct. CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Dear Tony Konkol and Esteemed Recipients, I am reaching out to seek your urgent assistance regarding actions taken by Oregon City's Code Enforcement Division that have significantly affected my health, well-being, and ability to work. I am the owner and resident of 12054 Chapin Ct. in Oregon City. On June 25, 2024, my water service was disconnected due to my inability to pay the minimum amount of $ 200. This situation has left me in a precarious position. Following the disconnection, I received a Code Violation Notice (Citation No. 113842) for a "dangerous building" and was verbally threatened with eviction within five days due to the lack of running water. Despite my offer to pay $ 724, the city has demanded a total of $ 1,919.08 to reconnect my service, which is beyond my financial means. The enforcement actions taken by Code Enforcement Officer Todd Kennedy have been excessively punitive, causing significant stress and anxiety, which have adversely impacted my sleep and work. I want to clarify that this situation is not due to neglect or irresponsibility. The water disconnection stems from financial hardship beyond my control. Furthermore, resources to meet basic living costs during this temporary financial strain are not as readily available as one might assume. In light of these circumstances, I respectfully request: 1. Mediation as an ADA Accommodation: The appointment of a mediator to facilitate constructive dialogue and work toward a fair solution. 2. Payment Plan Assistance: The establishment of a reasonable payment plan to restore my water service, improve my quality of life, and address the alleged code violation. 3. Review of Enforcement Tactics: A review of the approach taken by Code Enforcement Officer Todd Kennedy, which has escalated an already challenging situation. I appreciate your attention to this matter and am committed to positively contributing to our community. I trust that with your understanding and support, we can navigate these challenges in a fair and humane manner. Thank you for your consideration. Sincerely, Annika Eriksson 971-482-9185 cc: Tony Konkol, City Manager Denyse McGriff, Mayor Oregon City Commission Members Budget Committee Members Utility Billing Department Manager Code Enforcement Department Manager Municipal Court FOR Clackamas COUNTY ENTERED IN THE CIRCUIT COURT OF THE STATE OF OREGON JUDGE Tait, Eric James - Courtroom 8 FEB 0 4 2025 x February 03, 2025 - Monday By: TLR a 0 68:45 AM 024CV21417 Annika Eriksson P: Pro Se vs D: Hensrude, Gregor A; Hensrude, Gregor A; 0 Bank Of New York Mellon, Trustee for s CWALT 2006-0c10, NewRez LLC, All Other Unknown Parties 05/01/2024 Hearing - Motion Property - General ***Non-Oral; This is NOT a emailed partie? j tty Hen Svvay bray Case Title Relationship Room Disposition alime Case # Matter / Charge / Case Type Attorney Judge The Bank Of New York Mellon, Hensrude, Gregor A Trustee for CWALT 2006-0c11, The Hearing*** Pitf's Motion to e Dismiss Def's Counterclaim Judge Ene Jar t DA ASA Reporter ¥ Page lof1 Clerk no ra) 'ase # Matter / Charge / Case Type Attorney Judge > 0 vs D: Eagle, Chancelor; Hensrude, Gregor A; a Other Unknown Parties, The City of Oregon Cityetal. 05/01/2024 IN THE CIRCUIT COURT OF THE STATE OF OREGON ENTERED FOR Clackamas COUNTY C JUDGE Jones, Jeffrey S - Courtroom 5A AUG 06 2025 Au g ust 06, 2025 Wednesday By: AFS Case Title Relationship Room Disposition 9:00 PM N 994CV21417 Annika Eriksson P: Pro Se The Bank Of New York Mellon, Hensrude, Gregor A AI Hearing - Motion Property - General Page lofi Trustee for CWALT 2006-0c11, The Bank Of New York Mellon, Trustee for Proposed Intervenor: Donald Buckhout CWALT 2006-0c10, NewRez LLC, All No mode. 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24180_24CV21417-202-402-102-201