Case 2:21-cv-12871-MAG-APP ECF No. 35-2, PageID.

665 Filed 01/31/22 Page 1 of 7

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

David W. Williams, Chief Assistant Prosecutor

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.;

Amy M. Hopp, Esq. K By placing same in a sealed envelope addressed as

P.O. Box 941 stated and depositing same for pick-up service by
Defense Counsel or a Representative from Defense
Troy, MJ 48099-0941 Counsel's Office at the Oakland County Prosecutor's
Office.

Re: People v Ethan Robert Crumbley

CR 2022-279506-FC Natalie Nellett/Legal Secretary

Dear Mss. Loftin and Hopp:

Enclosed is a copy of one (1) 128GB flash drive containing the following discovery
materials, in regard to the above-captioned matter.

• Oakland County Sheriff’s Office Case report #210249546-001 through 210249546-242

(pages 1174-1542).
• Attachments (pages 1 543- 1551).
• Photos of Molly’s clothing (pages 1 552- 1 553).
• Photos of Phoebe’s clothing (pages 1554-1557).
• Photo of Kylie’s clothing (page 1 558).
• Photos of SD Card Evidence folder (pages 1559-1560).
. Photos of Justin Shilling’s clothing, key fob, and cell phone (pages 1561-1578).
• Photo of Riley Franz’s clothing (page 1579).
• Photos of Watson’s clothing (pages 1580-1582).
. Photo of outside bathroom looking in (page 1583).
• Photos of Watson’s clothing continued (pages 1 584- 1 585).
• Photo of live round found outside the bathroom (page 1 586).
• Photo of Watson’s shoes (page 1 587).
• Photo inside bathroom (page 1588).
• Photo of Watson’s shoes (page 1 589).
• Photo of Mueller’s backpack and shoes (pages 1590-1591).
•• Search Warrant Tabulation/Relurn (pages 1592-1596).
• Photos of outside of Crumbley household (pages 1597-1601 ).
• Photo of Heidi’s pants (page 1602).
. Photo of Flare gun (page 1603).
• Photos of Heidi’s pants continued (pages 1604-1605).
• Photos of shoe outside school window (pages 1606-1607).
• Photos of Ethan Crumbley (pages 1608-1612).
. Email from Becky Morgan to Nick Ejak and Shawn Hopkins regarding drawing from
11/30/21 and attached drawing (pages 1613-1614).
Case 2:21-cv-12871-MAG-APP ECF No. 35-2, PageID.667 Filed 01/31/22 Page 3 of 7

• Map and notes from Keegan Gregory (pages 1615-1616).

• Search Warrant and Affidavit for 1 1 2 E. Street (pages 1617-1 620).
• Search Warrant and Affidavit for T-Mobile phone records regarding: Ethan Crumbley
(pages 1622-1626).
. Map notes from Pamela Fine (page 1 627).
. Map notes from Brooke Bcrney (page 1 628).
• Map notes from Luke Bcrney (page 1 629).
• Photos of John Asciutto’s clothing (pages 1630-1638).
• Signed OCSO Authorization for Medical Release re: Aiden Watson (page 1639).
• Signed OCSO Authorization for Medical Release re: Ellijah Mueller (page 1 640).
• Photos of Aiden Watson and injury (pages 1 64 1-1642).
• Photos of Aiden* Watson call logs (pages 1643-1646).
• Photos of Justin Shilling’s text messages to Mom, Dad, and Sister (pages 1647-165 1).
• Photos of Justin Shilling’s group text (pages 1 652-1654).
• Jennifer Crumbley signed OCSO Consent to Search 1 12 E Street (page 1655).
• Witness statement from Jacquelin Brodt (page 1656).
• Witness statement from Keegan Gregory (pages 1657-1658).
. Keegan Gregory Family Text Messages (pages 1659-1663).
. Witness statement Angel Alicea-Rivera and SOS (pages 1664-1665).
. Witness statement Jeremy Alicea-Rivera and SOS (pages 1666-1 667).
• SOS of Miguel Alicea-Cortez (page 1668).
• SOS of Maria Rivera-Negron (page 1669).
. Drawing of bathroom by Keegan Gregory (page 1 670).
• Keegan Gregory Family Text Messages (pages 1671-1 676).
• Bathroom sketch (page 1 677).
• Ethan Crumbley ’s alleged Instagram account (page 1678).
• Picture of Ethan Crumbley provided by Keegan Gregory (page 1679).
• Snapchat account Keegan Gregory sent message to (page 1 680).
• Witness statement from Jacob Welc (page 1 681).
• Witness statement from Marcus Schroeder (page 1 682).
• Emailed statement from Bennett Covert (page 1683).
• Written statement from Bennett Covert (pages 1684-1685).
• Witness statement from Joshua Suable (page 1686).
• Witness statement from Anthony Jaboro (page 1687).
. Witness statement Logan Marshall (page 1688-1689).
• Logan Marshall’s text messages to mom (pages 1 690- 1691).
• Domonique Call’s call log with son Zachary Call (pages 1692-1693).
• Zachary Call’s text message to dad with his location (pages 1694-1695).
• Witness statement from Zachary Call (pages 1 696-1697).
• Witness statement from Dominque Call (pages 1 698-1699).
• Witness statement from Gavin Shafer (page 1 700- 1 70 1 ).
• Gavin Shafer’s text messages to mother and call log (pages 1702-1705).
• Photos from inside Oxford High School taken on 12/3/21 (pages 1706-1723).
• Driver’s License of Oxford School Staff Member (page 1724).
• Search Warrant Tabulation/Return for 2550 S. Telegraph Road (page 1 725).
• Map of 2550 S. Telegraph office (page 1726).
• Email from Boti Nemeth to Sergeant Dalbec (page 1727).
. Lake Orion Police Department report #210005512 and Evidence List (pages 1728-1733).
. Photos of Crumbley family dog (pages 1734-1736).
. Facebook messenger conversation between Jennifer Crumbley and neighbor Sandra Priest
(pages 1737-1745).
. Facebook messenger communication from “Travis” (pages 1746-1747).
Case 2:21-cv-12871-MAG-APP ECF No. 35-2, PageID.668 Filed 01/31/22 Page 4 of 7
Statement from Anthony Geirak (pages 1748-1749).
Statement from DNR officer (page 1750).
Grand Blanc Township report #2185204187 (pages 1751-1752).
Witness statement from Kendall Stewart (page 1753).
Ethan Crumblcy historical school records (pages 1754-1786).
3200 form (pages 1787-1788).
Photo of suspect’s gun and loaded magazine (page 1789).
Photos of inside of wall where bullet entered (page 1790).
Photo of Ms. Jasinski’s classroom #256 (page 1791).
Photo of bullet (page 1792).
Photos inside Oxford High School where bullets were recovered from (pages 1793-1805).
Diagram drawn by Ken Weaver (page 1 806).
Screenshots from Ms. Pennock (pages 1 807-18 1 0).
Adobe coversheet (page 1811).
Jennifer Crumbley Text Messages (pages 1812-1817).
Witness Statement from Kenneth Weaver (pages 1818-1824).
Witness Statement from Claude Lafnear and Oxford Bowling Roster 20-2 1 yr (pages 1 825-
1826).
Royal Oak PD Case report #2 10039083 (pages 1827-1828).
Email from Deputy Police Chief Mike Frazier for Royal Oak PD (page 1 829).
Oxford High School Victim List with Caregivers and Agencies (pages 1830-1831).
Oxford Fire Department Personnel Response to High School Shooting (pages 1 832-1833).
Email from Independence Fire Department Business Manager Renee Herbert (page 1 834).
Letter from Charter Township of Orion Fire Department to Sgt. Werner (page 1 835).
Orion Township Fire Department Patient Care Record for victim Riley Franz (pages 1 836-
1839).
Email from Brandon Fire Department Fire Chief David Kwapis (page 1840).
Email from Fire Chief Jeremy Lintz, North Oakland County Fire Authority and attacluncnt
(pages 1841-1845).
Bloomfield Township Fire Department Incident No. 210005824 report and Supplemental
report (pages 1846-1850).
Ethan Crumbley’s ELA Survey from Ms. Kubina and scanned index card (pages 1851-
1854).
Screenshots of messages from Ms. McConnell to Shawn Hopkins (pages 1855-1857).
Emails from Jill Lemond to Saso Vasovski (pages 1858-1863).
Screenshot of messages from Ms. Karpinski to Pamela Fine and Shawn Hopkins (pages
1864-1865).
Email obtained from Jill Lemond regarding email sent from Anthony Gierak to Kim
Monkevich (page 1 866).
Screenshot of email thread containing photos of index card (page 1867).
Email and attachment regarding OHS Absent Report (pages 1868-1870).
OCSO Inbound Evidence Transfer Receipt (pages 1 871-1872).
Images of backpack that bullet had been shot through (pages 1873-1876).
Witness Statement from Jaiden Hatchew (page 1877).
MSP Incident report #SIS-275-21 dated 12/08/21 (pages 1878-1880).
MSP Incident report #034-4887-21 dated 11/30/21 (page 1881).
MSP Supplemental 0001 report #034-4887-21 dated 12/6/21 (page 1882).
MSP Supplement 0002 report #034-4887-21 dated 12/2/21 (page 1883).
MSP Incident report #EST- 1047-21 dated 11/30/21 (pages 1884-1885).
MSP Incident report #CAN-5933-21 dated 11/30/21 (pages 1886-1887).
MSP Supplemental 0001 report #CAN-5933-21 dated 12/01/21 (page 1888).
MSP Supplemental 0002 report #CAN-5933-21 dated 12/7/21 (page 1889).
Case 2:21-cv-12871-MAG-APP ECF No. 35-2, PageID.669 Filed 01/31/22 Page 5 of 7

• MSP Incident report #21-1 1229-21 dated 1 1/30/21 (pages 1890-1902).

. MSP Supplemental 0001 report #21-1 1229-21 dated 1 1/30/21 (pages 1903-1917).
• MSP Supplemental 0002 report #21-1 1229-21 dated 1 1/30/21 (pages 191 8-1947).
. MSP Supplemental 0003 report #21-1 1229-21 dated 1 1/30/21 (pages 1948-1960).
• EMS run sheet (pages 1961-1967).
• MedStar Ambulance Michigan Patient Care Record for Phoebe Arthur (pages 1 968- 1980).
• MedStar Ambulance Patient Transfer for Phoebe Arthur (pages 1981-1 982).
• McLaren Patient Record for Phoebe Arthur (page 1 983).
• Novi PD report #210060122 (page 1984).
• Rochester Hills Fire Incident No. 210007054 (pages 1 985-1 994).
• Troy Police Department report #210032391 (pages 1995-2002).
• West Bloomfield’Fire Department Incident No. 2 1 0006 134 (pages 2003-2004).
• Star EMS Patient Care Record Narrative report (pages 2005-2006).
• Lapeer Police Department report #2 1 0007270 (page 2007).
• Screenshot of Instagram post by Chandan Varner (page 2008).
• Screenshot of Snapchat posts (page 2009-20 1 0).
• Screenshot of text message (page 2011).
• OCSO Snapchat Preservation Letter and attached email (pages 20 1 2-20 1 4).
• Map of OHS with notes (page 2015).
• Names and numbers of Students/Teachers (pages 2016-20 1 7).
• Signed Order Compelling Buccal Swab and Signed Stipulation and Order for Buccal Swab
for Ethan Crumbley (pages 2016-2021).
• OCSO Inbound Evidence Transfer Receipt for buccal swab (page 2022-2023).
• Names of Students/Teachers (pages 2024-2028).
• Search Warrant and Affidavit for Flagstar Bank Records (pages 2029-2033).
• Search Warrant and Affidavit for Mission Lane Records (pages 2034-203 8).
• Search Warrant and Affidavit for Mastercard Records (pages 2039-2043).
• Search Warrant and Affidavit for Bank of America Records (pages 2044-2048).
• Evidence List (pages 2049-205 1 ).
• OCSO Supplemental report #210249546-190 (with readable narrative) and Evidence List
(pages 205 1-2054).
• OCSO Supplemental report #2 1 0249546-243 and Evidence List (pages 2055-2057).
• OCSO Supplemental report #2 1 0249546-244 and Evidence List (pages 2058-2060).
• OCSO Supplemental report #21 0249546-245 and Evidence List (pages 2061-2063).
• OCSO Supplemental report #210249546-246 and Evidence List (pages 2064-2068).
• OCSO Supplemental report #2 1 0249546-247 and Evidence List (pages 2069-2071).
• OCSO Supplemental report #210249546-248 and Evidence List (pages 2072-2074).
• OCSO Supplemental report #210249546-249 and Evidence List (pages 2075-2077).
• OCSO Supplemental report #2 1 0249546-250 and Evidence List (pages 2078-2080).
• OCSO Supplemental report #210249546-251, Attachments, Electronic Crimes Special
Agent Program Summary Report, United States Secret Service Unlocking/Extraction
Notes, FBI reports regarding cell phone, FBI Technical Assistance report, and Evidence
List (pages 2081-2095).
• OCSO Supplemental report #2 1 0249546-252, Attachments, email ofphoto of bird head in
jar, and Evidence List (pages 2096-2100).
• OCSO Supplemental report #210249546-253, Attachments, OHS layout with notes from
Kaena Anderle, and Evidence List (pages 21 01-2105).
• OCSO Supplemental report #2 1 0249546-254 and Evidence List (pages 2 1 06-2 1 07).
• Witness Statements collected (pages 2 1 08-2 171).
• MSP Incident report #BMB-367-21 dated 12/01/21 (pages 2172-2174).
• MSP #BMB-367-2 1 Color Photos of Backpack (pages 2 1 75-2 1 80).
. MSP #BMB-367-21 Radiograph Images (pages 2181-2185).
Case 2:21-cv-12871-MAG-APP ECF No. 35-2, PageID.670 Filed 01/31/22 Page 6 of 7

. FBI Interview of Ayden Johnson (page 2 1 86).

. FBI Report dated 12/16/21 regarding Cellebrite (page 2187).
• FBI Report dated 1 2/1 7/2 1 regarding Officer Tindell (page 2 1 88).
• Search Warrant and Affidavit for Flagstar Bank Records (pages 2 1 89-2 1 93).
• Search Warrant and Affidavit for Mission Lane Records (pages 2194-2198).
• Search Warrant and Affidavit for Mastercard Records (pages 2199-2203).
• Search Warrant and Affidavit for Bank of America Records (pages 2204-2208).
• ATF Report No. 8 - Interview of Nicole Ellsworth and Screenshots of Facebook
Messenger and Text Messages (pages 2209-2277).
• ATF Report No. 9 - Nick Ejak Statements (page 2278).
• ATF Report No. 10 - Interviews of Tyler Heichel and Diner Employees (pages 2279-
2280).
• ATF Report No.-4 1 - Interview of Elijah Crumbley and Cheryl Cobb (pages 2281-2284).
• Autopsy Cover Sheets for Madisyn Baldwin, Tate Myre, Justin Shilling and Hana St.
Juliana, Autopsy Protocol Request, and Property Release Forms (pages 2285-2296).
. Search Warrant and Affidavit for DoorDash (pages 2297-2304).
• Search Warrant and Affidavit for Ethan Crumbley’s Phone (pages 2305-2309).
• Search Warrant and Affidavit for YouTube Account of Ethan Crumbley (pages 2310-
2317).
• Search Warrant and Affidavit for YouTube Account of James Crumbley (pages 2318-
2325).
• Search Warrant and Affidavit for Facebook Account records for Jennifer Crumbley
(JCRumbley) (pages 2326-2340).
• Search Warrant and Affidavit for Facebook Account records for Jennifer Crumbley
(jelin. crumbley. 7) (pages 2341-2355).
• Search Warrant and Affidavit to Google for records re: 5263 1 @oxfordwildcats.org (pages
2356-2365).
• Search Warrant and Affidavit to Google for records re: Ethan, James, and Jennifer’s email
accounts (pages *2366-2374).
• Search Warrant and Affidavit to Google for records re: Jennifer Crumbley email accounts
(pages 2375-2387).
• Search Warrant and Affidavit to Instagram regarding account: daddy vderr (pages 2388-
2393).
• Search Warrant and Affidavit to Instagram regarding account: James R. Crumbley (pages
2394-2402).
. Search Warrant and Affidavit to Instagram regarding account: jchnc78 (pages 2403-2409).
• Search Warrant’ and Affidavit to Instagram regarding accounts: ethan.crumbleyy,
ethan.crumbley, ethan_crumblcy, and ethancrumbley_ (pages 2410-2414).
• Search Warrant and Affidavit for TMobile tower records for phone #947-300-8464 (pages
2415-2428).
• Search Warrant and Affidavit for TMobile Tower records for James and Jennifer
Crumbley’s cell phones (1) (pages 2429-2441).
• Search Warrant and Affidavit for TMobile Tower records for James and Jennifer
Crumbley’s cell phones (2) (pages 2442-2455).
. Search Warrant and Affidavit for TMobile Tower records for Ethan Crumbley’s cell phone
(pages 2456-2468).
• Search Warrant and Affidavit for Yahoo email records for James Crumbley (pages 2469-
2476).
• Search Warrant and Affidavit for Yahoo email records for Jennifer Crumbley (pages 2477-
2484).
. Search Warrant and Affidavit to YouTube (pages 2485-2489).
 Case 2:21-cv-12871-MAG-APP ECF No. 35-2, PageID.671 Filed 01/31/22 Page 7 of 7

• 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).

I am also enclosing the following video files:

• Folder titled: BMB-367-21 containing video footage of MSP’s bomb robot

• Folder titled: Ethan- s Cell Phone containing the cell phone analysis
• Folder titled; Interviews
o Jacquelyn Kubina
o Keegan Gregory (x2)
o Pamela Fine
o Shawn Hopkins
• Folder titled: James’ Cell Phone
o James Crumbley cell phone examination report dated December 9, 2021, for case
#21-249546 by Det. J. Bois for T-Mobile 5007Z (5 pages).
• Folder titled: Jennifer Crumbley in-car video outside home
• Folder titled: Jennifer’s Cell Phone(s)
o Jennifer Crumbley cell phone examination report dated December 4, 202 1 , for case
#21-249546 by Det. J. Bois for Motorola Moto G8 (5 pages).
o Jennifer Crumbley cell phone examination report dated December 13, 2021, for
case #21-249546 by Det. J. Bois for LG LG-D850 (2 pages).
• Folder titled: Oxford Sub Interviews
o Video of Ethan
o Video of Parents

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

Dear Wildcat Nation,

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.

10 N. Washington St. Oxford, MI 48371 I Ph. 248.969.5000 I Fax 248.969.5013 I www.oxfordschools.org

Non-Discrimlnatlon Clause: Oxford Community Schools does not discriminate on the basis of race, color, religion, national origin, sex (sexual orientation or gender), disability, age, 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, (248) 969-5004.
 Case 2:21-cv-12871-MAG-APP ECF No. 35-3, PageID.674 Filed 01/31/22 Page 3 of 4
2

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

10 N. Washington St. Oxford, MI 48371 / Ph. 248.969.5000 I Fax 248.969.5013 / www.oxfordschools.org

Non-DIscrImlnatlon Qium: Oxford Community Schools does not discriminate on the basis of race, color, reSglon, national origin, sex (sexual orientation or gender), disability, eye, height, weight, marital status or any other legally protected
charactertitlc, In Iti programs, services or activities, Including employment opportunities. The following person has been designated to handle Inquiries regarding the nondscrimlnatlon policies:
Assistant Superintendent of Human Resources, 10 North Washington Street, Oxford, Ml 4U71, <248) 959-5004.
Case 2:21-cv-12871-MAG-APP ECF No. 35-4, PageID.676 Filed 01/31/22 Page 1 of 2

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

January 27, 2022

James J.' Harrington, IV

Fieger, Fieger, Kenney & Harrington, PC
19390 West Ten Mile Rd.
Southfield, MI 48075
Re: Civil Oxford Cases
Defendants ’ Requestfor a Stay

-Sent by e-mail-

Dear Mr. Harrington:

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.

Very truly yours,

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

ATTORNEYS AND COUNSELORS AT LAW

19390 West Ten Mile Road

Southfield, Michigan 48075-2463

Telephone (248) 355-5555

FAX (248) 355-5148

Website: www.fiegerlaw.com
Nora Y. Hanna Direct Dial (248) 945-7519

E-Mail: [email protected]

January 28, 2022

Via E-Mail
Nicole Tabin
[email protected]

RE: Oxford Cases

FOIA

Dear Ms. Tabin,

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.

I look forward to speaking with you next week.

Very Truly Yours,

Fieger, Fieger, Kenney & Harrington, P.C.

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

PEOPLE OF THE STATE OF MICHIGAN,

Plaintiff,

vs. Case No. 22-279506-FC

ETHAN FT CRUMBLEY, HON. KWAME ROWE

CD
CXI
Defendant.
CM
O
CM

CM KAREN MCDONALD P59083

T“*
OAKLAND COUNTY PROSECUTOR
1200 N. '
if
Jg PONTIAC, MI 48341
o
PAULETTE MICHEL LOFTIN P71982
c
ATTORNEY FOR DEFENDANT
o 145 S. LIVERNOIS #183
O
0
ROCHESTER, MI 48307
c

AMY HOPP P48872

co
ATTORNEY FOR DEFENDANT
O
PO BOX 941
O) TROY, Ml 48099
c

U. DEBORAH H. MCKELVY P44157

COURT APPOINTED GAL
s
1432 MARYLAND BLVD.
CD
> BIRMINGHAM, MI 48009
q
o /
CD
a:
NOTICE OF INSANITY DEFENSE

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

gives notice of his intention to claim such a defense.

Date Respectfully Submitted.

A
fL_,A J
Paulette Michel Loftin PTWfc
Attorney for Defendant

_ _ 1 . -
Amy Hopp P48872 D
Attorney for Defendant