Professional Documents
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Exhibits, Oxford Lawsuit
Exhibits, Oxford Lawsuit
Exhibit 1
(00673795. DOCX}
Case 2:21-cv-12871-MAG-APP ECF No. 35-2, PageID.666 Filed 01/31/22 Page 2 of 7
KAREN D. MCDONALD
Office of the Prosecuting Attorney, Oakland County Michigan
1200 North Telegraph Road • West Wing, Building 14- E Pontiac, Michigan 48341
Phone:248-858-0656 • Fax:248-858-0660
January 1 0, 2022
PROOF OF SERVICE
Paulette M. Loftin, Esq. I, Natalie Nellett, being duly sworn, depose and say
145 S. Livernois Road, #183 that on January 10, 2022, the referenced item(s) were
provided to:
Rochester, MI 48307-1837
Paulette Michel Loftin, Esq. & Amy M. Hopp, Esq.;
Enclosed is a copy of one (1) 128GB flash drive containing the following discovery
materials, in regard to the above-captioned matter.
• Search Warrant and Affidavit for Transportation Alliance Bank Records (pages 2490-
2494).
• Search Warrant and Affidavit for Sutton Bank Records (pages 2495-2499).
• OCSO case report #210230222 regarding the Deer Head incident, Attachments, color
photos, statement, and evidence list (pages 2500-2515).
Sincerely,
KAREN D. MCDONALD
PROSECUTING ATTORNEY
Kelly M. Collins
Assistant Prosecuting Attorney
MC/nn
Case 2:21-cv-12871-MAG-APP ECF No. 35-3, PageID.672 Filed 01/31/22 Page 1 of 4
Exhibit 2
{00673795.DOCX}
Case 2:21-cv-12871-MAG-APP ECF No. 35-3, PageID.673 Filed 01/31/22 Page 2 of 4
OXFORD COMMUNITY SCHOOLS
Tim Throne, Superintendent
J.1
Ken Weaver, Deputy Superintendent of Curriculum & Instruction
Anita Qonja-Collins, Assistant Superintendent of Elementary Instruction
Sam Barna, Assistant Superintendent of Business & Operations
/SCHOOLS*? David Pass, Assistant Superintendent of Human Resources
WHKKL* THE GLOBE JH UVK CAMPUS Jill Lemond, Assistant Superintendent of Student Services
We would like to express our continued grief and anguish at the tragic events of the past week. The
shooting at Oxford High School has tested the resolve of our students, families and staff like never
before.
Our Wildcat community has been shaken to its core, and our hearts are with the families impacted by
this unthinkable tragedy and those still recovering from their injuries. Please keep the victims and
families in your thoughts and prayers.
When this unthinkable tragedy unfolded on the afternoon of Nov. 30, our staff and students acted
swiftly and heroically, which undoubtedly prevented additional deaths and additional injuries by
implementing our District's detailed emergency protocols and procedures. We cannot thank our
students and staff enough for their quick and decisive actions and their bravery. We are also
immensely thankful for the first responders, who responded quickly and literally ran into harm's way to
prevent even more lives from being lost.
As many of you know, the first shots were fired during passing time between classes when hundreds of
students were in the hallway transitioning from one classroom to the other. Before the shooter was
able to walk a short distance to enter the main hallway, students and staff had already entered
classrooms, locked doors, erected makeshift barricades and locked down or fled according to their
training. The suspect was not able to gain access to a single classroom.
We have asked an independent security consultant to review all district safety practices and
procedures. An initial review including review of videotaped evidence show staff and students'
response to the shooter was efficient, exemplary and definitely prevented further deaths and injuries.
In response to family concerns, we have also begun the process of reviewing attendance records prior
to this event as well as collecting and reviewing any and all communications that the district may have
received. At this time, we agree with the Oakland County Sheriffs Office assessment that previous
incidents, including those addressed in the Nov. 12 communication to families, are unrelated to the
events of Nov. 30.
Following yesterday's press conference by the Oakland County Prosecutor, many of our parents have
understandably been asking for the school's version of events leading up to the shooting. It's critically
important to the victims, our staff and our entire community that a full and transparent accounting be
made. To that end, I've asked for a third-party investigation be conducted so we leave no stone
unturned, including any and all interaction the student had with staff and students. Because that may
take time, we wanted to provide some additional specific information about the events that
transpired.
On Nov. 29, the suspect was discovered by a teacher to be viewing images of bullets on his cell phone
during class. The suspect met with a counselor and another staff member and indicated he and his
mother recently went to the shooting range and that shooting sports are a family hobby. Consistent
with our school policies and procedures, the school attempted to make contact with the student's
mother to discuss the incident but did not initially hear back. The next day, his parents confirmed his
account.
On the morning of Nov. 30, a teacher observed concerning drawings and written statements that have
been detailed in media reports, which the teacher reported to school counselors and the Dean of
students. The student was immediately removed from the classroom and brought to the guidance
counselor's office where he claimed the drawing was part of a video game he was designing and
informed counselors that he planned to pursue video game design as a career. The student's parents
were also called in. Because it was difficult to reach the parents, the student remained in the office for
an hour and a half while counselors continued to observe, analyze and speak with the student. While
waiting for his parents to arrive, the student verbalized his concern he would be missing homework
assignments and requested his science homework, which he then worked on while in the office. At no
time did counselors believe the student might harm others based on his behavior, responses and
demeanor, which appeared calm. In addition, despite media reports, whether or not the gun was in his
backpack has not been confirmed by law enforcement to our knowledge nor by our investigation at
this time.
While both of his parents were present, counselors asked specific probing questions regarding the
potential for self-harm or harm to others. His answers, which were affirmed by his parents during the
interview, led counselors to again conclude he did not intend on committing either self-harm or harm
to others. The student's parents never advised the school district that he had direct access to a firearm
or that they had recently purchased a firearm for him.
Counseling was recommended for him, and his parents were notified that they had 48 hours to seek
counseling for their child or the school would contact Child Protective Services. When the parents were
asked to take their son home for the day, they flatly refused and left without their son, apparently to
return to work.
Given the fact that the child had no prior disciplinary infractions, the decision was made he would be
returned to the classroom rather than sent home to an empty house. These incidents remained at the
guidance counselor level and were never elevated to the principal or assistant principal's office. While
we understand this decision has caused anger, confusion and prompted understandable questioning,
the counselors made a judgment based on their professional training and clinical experience and did
not have all the facts we now know. Our counselors are deeply committed longstanding school
members who have dedicated their lives to supporting students and addressing student mental health
and behavioral issues.
djjjjfei 10 N. Washington St. Oxford, MI 48371 I Ph. 248.969.5000 I Fax 248.969.5013 / www.oxfordschools.org
Non-Olsaknlnatlon Clause: Oxford Community School! dots not discriminate on the basis of race, color, religion, national origin, sex (sexual orientation or gender), disability, ege, height, weight, marital status or any other legally protected
characteristic, In Its programs, services or activities, Including employment opportunities. The following person has been designated to handle Inquiries regarding the nondiscrimination policies:
Assistant Superintendent of Human Resources, 10 North Washington Street, Oxford, Ml 48371, (243) 969-5004,
Case 2:21-cv-12871-MAG-APP ECF No. 35-3, PageID.675 Filed 01/31/22 Page 4 of 4
3
Again, I have personally asked for a third-party review of all the events of the past week because our
community and our families deserve a full, transparent accounting of what occurred. We also plan to
make regular updates to our families and community. Trained mental health professionals and grief
counselors with experience in coping with school tragedies are available for anyone who needs support
at this difficult moment. Information about counseling is available on the districts website.
We have been asked by some parents regarding our plans for continuing our children's learning and
education in the wake of this tragedy. We have already begun to discuss the appropriate path and
timeline with trained grief counselors, safety experts, law enforcement, our school employees and our
families on the best way to help our community grieve, process, be together, and continue their
education.
Thank you again for your outpouring of love and support for our Wildcat families during this incredibly
difficult time. The unparalleled support from our community and neighboring communities gives me
hope that we can and will persevere and emerge stronger. Please continue to pray for the victims and
their families, the injured and pray for the strength to carry on in the days ahead.
Oxford StrOng,
Tim
Exhibit 3
{00673795.DOCX}
Case 2:21-cv-12871-MAG-APP ECF No. 35-4, PageID.677 Filed 01/31/22 Page 2 of 2
&
Smith Lehman, PC Shannon Smith, Esq..
1668 South Telegraph Road Mariell Lehman, Esq..
Suite 200 Phone: (248) 636-2595
Bloomfield Hills, MI 48302 www.smith-lehman.com
SMITH LEHMAN
-Sent by e-mail-
As you know, our office represents James and Jennifer Crumbley regarding the pending
criminal charges filed against them. Mr. and Mrs. Crumbley have been charged in Oakland County
with four counts of involuntary manslaughter after the school shooting that look place at Oxford
High School on November 30, 2021.
Our office has reviewed the Motion to Stay Proceedings Pending the Conclusion of the
Parallel Criminal Cases filed by the defendants in your civil case. We find it very concerning that
the Defendants claim the “Oakland County Prosecutor directed counsel for the Defendants to avoid
releasing information related to the within matter so as to prevent any interference with the ongoing
criminal proceedings.” It is our position that the full exchange of discovery and materials, both in
the civil cases and the criminal cases, best serves the interest of justice for all parties. Our clients
agree that access to all documents and all records is critical to all of the litigants involved. As such,
we do not support the request for a stay in the civil matter, nor do we join the civil defendants in
their request for a stay. We do not believe that the civil matters proceeding forward interferes with
our clients’ rights to a fair trial in any way.
Please feel free to call our office if you have any questions.
Shannon M. Smith
Mariell Lehman
Case 2:21-cv-12871-MAG-APP ECF No. 35-5, PageID.678 Filed 01/31/22 Page 1 of 2
Exhibit 4
{00673795.DOCX)
Case 2:21-cv-12871-MAG-APP ECF No. 35-5, PageID.679 Filed 01/31/22 Page 2 of 2
Fieger, Fieger, Kenney & Harrington
A PROFESSIONAL CORPORATION
Website: www.fiegerlaw.com
Nora Y. Hanna Direct Dial (248) 945-7519
E-Mail: [email protected]
This letter confirms our January 25, 2022, conversation. The conversation addressed the
FOIA requests that our office had properly served on the Oakland County Sheriff s Department
as well as the Oakland County Prosecutor’s Office. During our conversation, you confirmed the
existence of documents that could be disclosed without impeding the Defendants right to a fair
trial however, you could not produce any records or items pursuant to our FOIA request. You
indicated that in the event documents are produced to our office pursuant to FOIA, you would be
required to produce the documents to the press and other entities. You also indicated in the event
we served you with a subpoena compelling the production of the same materials, you would
produce documents consistent with the subpoena.
Nora Y. Hanna
{01 23 13 1 5. DOCX)
Case 2:21-cv-12871-MAG-APP ECF No. 35-6, PageID.680 Filed 01/31/22 Page 1 of 3
Exhibit 5
{00673795.DOCX)
Case 2:21-cv-12871-MAG-APP ECF No. 35-6, PageID.681 Filed 01/31/22 Page 2 of 3
STATE OF MICHIGAN
IN THE 6th CIRCUIT COl IRT IN THE COUNTY OF OAKLAND
Plaintiff,
a
LLJ TO: KAREN MCDONALD P59083
OAKLAND COUNTY PROSECUTOR
uZ
1200 N. Telegraph Rd
Pontiac, MI 48341
Case 2:21-cv-12871-MAG-APP ECF No. 35-6, PageID.682 Filed 01/31/22 Page 3 of 3
PLEASE TAKE NOTICE that pursuant to MCL 769.20a, the Defendant ETHAN
CRUMBLE Y, intends to assert the defense of insanity at the time of the alleged
offense and
A
fL_,A J
Paulette Michel Loftin PTWfc
Attorney for Defendant
_ _ 1 . -
Amy Hopp P48872 D
Attorney for Defendant