In the Circuit Court of the State of Oregon For Multnomah County | Court Nbr 20-CR-03885 DA 2416790-1 STATE OF OREGON Crime Report PP 20-22195 Plaintiff, Information of District Attorney HAYLEY RENEE MORGAN JEAN Does 1202/98 ons 163.165 (12) Ons 8130108) ‘ORS 811.140 (4) FLED ORS 1819518 ° JAN 21 2019 Deendan) CIRCLAT COURT ‘The above-named defendant(s) is accused by this information of the crime(s) of COUNT I - ASSAULT IN THE THIRD DEGREE (CLASS B FELONY), COUNT 2 - ASSAULT IN THE THIRD DEGREE, COUNT 3 - MISDEMEANOR DRIVING WHILE UNDER THE INFLUENCE OF INTOXICANTS, COUNT 4 - RECKLESS DRIVING, COUNT 5 - RECKLESSLY ENDANGERING ANOTHER PERSON, committed as follows: COUNT ASSAULT IN THE THIRD DEGREE (CLASS B FELONY) ‘The said Defendant(s), HAYLEY RENEE MORGAN JEAN, on or about January 20, 2020, in the County of Multnomah, State of Oregon, did unlawfully and recklessly cause serious physical injury to Barbara Ann Stuva by means ofa vehicle, a dangerous ‘weapon, contrary to the statutes in such cases made and provided and against the peace and dignity ofthe State of Oregon. ‘This count is connected together by two or more acts of transactions with the other count(s) of this charging instrument. This count is ofthe same and similar character as the conduct alleged inthe other count(s) of this charging instrument, This count constitutes part of a common scheme or plan based on two or more acts or transactions with the other count(s) of this charging instrument. counT2 ASSAULT IN THE THIRD DEGREE “The said Defendant(s), HAYLEY RENEE MORGAN JEAN, on or about January 20, 2020, inthe County of Multnomah, State of Oregon, did unlawfully and recklessly cause serious physical injury to Barbara Ann Stuva by means of aa vehicle, a dangerous ‘weapon contrary tothe statutes in such cases made and provided and against the peace and dignity ofthe State of Oregon. ‘This count is connected together by two or more acts or transactions with the other count(s) of this charging instrument. This ‘count is of the same and similar character as the conduct alleged in the other count(s) ofthis charging instrument, This count constitutes part of a common scheme or plan based on two or more acts or transactions with the other count(s) of charging instrument. COUNT3 MISDEMEANOR DRIVING WHILE UNDER THE INFLUENCE OF INTOXICANTS. ‘The said Defendant(s), HAYLEY RENEE MORGAN JEAN, on or about January 20, 2020, in the County of Multnomah, State of Oregon, did unlawfully drive a vehicle upon a public highway and premises open to the public, while under the influence of a controlled substance, contrary to the statutes in such cases made and provided and against the peace and dignity of the State of Oregon, ‘This count is connected together by two or more acts or transactions with the other count(s) of this charging instrument. This count is ofthe same and similar character as the conduct alleged in the other counts) ofthis charging instrument. This count constitutes part of a common scheme or plan based on two or more acts or transactions with the other count(s) ofthis charging instrument. resoret INFORMATION OF DISTRICT ATTORNEY Ht NLUPage 2 Defendant: Hayley Renee Morgan Jean , Court Nbr 20-CR-03885 COUNTS RECKLESS DRIVING “The said Defendant(s), HAYLEY RENEE MORGAN JEAN, on or about January 20, 2020, in the County of Multnomab, State of Oregon, did unlawfully and recklessly drive a vehicle upon a public highway and premises open to the public, in a ‘manner that endangered the safety of persons or property, contrary to the statutes in such cases made and provided and against the peace and dignity of the State of Oregon, This count is connected together by two or more acts or transactions with the other count(s) of this charging instrument. This count is ofthe same and similar character as the conduct alleged in the other counts) of this charging instrument. This count constitutes part of a common scheme or plan based on two or more acts or transactions with the other count(s) of this charging instrument. Correet Copy of COUNTS RECKLESSLY ENDANGERING ANOTHER PERSON ‘The said Defendant(s), HAYLEY RENEE MORGAN JEAN, on or about January 20, 2020, in the County of Multnomah, State of Oregon, did unlawfully and recklessly create a substantial risk of serious physical injury to another person , contrary to the statutes in such cases made and provided and against the peace and dignity of the State of Oregon, ‘This count is connected together by two or more acts or transactions with the other count(s) of this charging instrument. This ‘count is of the same and similar character as the conduct alleged in the other count(s) of this charging instrument. This count constitutes part of a common scheme or plan based on two or more acts or transactions with the other count(s) of this charging instrument. Dated at Portland, Oregon, in the county aforesaid, on JANUARY 21, 2020. CROCKETT OSB 131107 ROD UNDERHILL (883246) District Attomey Multnomah County, Oregon B Issuing Dephity, an Security Amount (Def - JEAN) $20,000 + $5,000 + $2,500 + $2,500 + $2,500 Uniform Complaint AFFIRMATIVE DECLARATION “om Dit tray rcbyafemativey defor ies eu by ORS 6146, ypon he ae chee othe ft open of te defendant, ad befor te TEPESAEGRS 15 toa how te detent plo ae harp) te Ses men hat ny misdemeanr carp! Deri teed msec Pursuant to 2005 Or Laws ch, 463 sections 1 10 7, 20(1) and 21 to 23, the State hereby provides writen notice of the State's intention to rely at sentencing on enhancement facts for any statutory ground forthe imposition of consecutive sentences codified under ORS 137.123, ‘on these counts of to any other sentence which has been previously imposed or is simultaneously imposed upon this defendantIn the Circuit Court of the State of Oregon for Multnomah County Cour Nbr 20-CR-03885_ DA 2416790-1 STATE OF OREGON, Crime Report PP 20-22195 Plinti, v. PROCACLEABADSAT OF PROBABLE CAUSE SSN) PI NTOSERPGNEPONTINUED DETENTION HAYLEY RENEE MORGAN JEAN OF DEFENDANT FILE: DOB: 12/22/1984 99 020 ‘> ine Odor JAN 21 2019 Defendant(s), JUSGE ee cmcUT Coury 1, Ashly H. Crockett, swear that | am a Deputy District Attomey for Multnomah County and that I have reviewed the police reports which have been filed in this case by police officers; that the crimes charged against defendant(s) occurred in Multnomah County and that the probable cause for detention following the arrest of defendant(s) is as follows: Thave reviewed the reports written by Portland Police Officer Huntly Miller, and know that on January 20, 2020, Officers responded to a report of a erash at approximately 1:17pm. Officer Miller wrote that when he arrived on scene in the 14800 block of SE Steele Street he learned that the victim, Barbara Ann Stuva, was accessing the trunk of her properly-parked ccar when the defendant crashed her car into Ms, Struva, pinning her between the two vehicles and crushing her legs; Officer Miller noted that the victim is 75-years-old, was transported by ambulance, and may need to have her legs amputated in the ‘coming days due to the severity of her injuries. Officer Miller wrote that he noted that the defendant exhibited signs of impairment, including flat affect, relaxed muscles and facial tone, glassy eyes, slow and slurred speech with delayed responses and poor enunciation, and swaying when walking and standing, however he did not note any odor of aleoho!; defendant stated that she is "on Methadone” and officer Miller wrote that during the course of his interactions with her, he ‘observed recent injection sites on defendant's body. Officer Miller wrote that the defendant produced bottles labeled as ‘Methadone from the ear. Officer Miller stated that he conducted Standard Field Sobriety Tests, which defendant failed, and determined that the defendant was under the influence of a controlled substance and/or alcohol. Officer Miller noted that during the course of his investigation the defendant fell sleep many times, appeared disinterested and unconcemed with the vietim’s condition, [believe there is probable cause to believe the defendant, HAYLEY RENEE MORGAN JEAN, has committed the erime(s) of, COUNT 1 - ASSAULT Ill (DUII - RECKLESS/SERIOUS PHYSICAL INJURY W/ WEAPON), COUNT 2 - ASSAULT Ill (RECKLESS/SERIOUS PHYSICAL INJURY W/ WEAPON), COUNT 3 - DUI - MISDEMEANOR (CONTROLLED SUB/INHALANTICOMBO), COUNT 4 - RECKLESS DRIVING and COUNT 5 - RECKLESSLY ENDANGERING ANOTHER PERSON, pate_1{ 22/2020 at Signature Ashly H. Crockett, DDA, OSB# 131107 ‘SUBSCRIBED AND SWORN TO BEFORE. a ME ON THE ABOVE DATE: P rotary pate A On rublic Fr Oregon: ‘OREGON greene (09/2 pent etre = AFFIDAVIT OF PROBABLE CAUSE ‘Adaat ~ Probable Cause Taa04651 a UM