Open Letter: To Washington County Criminal Court, Pleadings


Washington County Cpourthouse — Criminal Court

In the matter of,

I. Defendant seeks to have the plea bargain of February 16, 2005 dismissed and have all record and fees of this matter expunged.

A. Defendant was given a felony conviction by the court, and received five years probation. As part of the plea bargain, defendant was required to register as a “low risk sex offender”, for life. This punishment was grossly unfair and unconstitutional based on the facts in the case, as described in the enclosed attachment, “3 Americas”.

B. Defendant’s physical impairments, along with the hostility toward all sex offenders, regardless of their level, has made this burden extremely unjust, in light of any public interest it may serve.

II. The Supreme Court ruled that in all felony cases it is unconstitutional to be convicted by a jury that is not unanimous. Defendant would argue that the Court’s decision should also apply to a plea bargain, that had been made under these circumstances, since the threat of a unconstitutional conviction played a role in Defendant’s accepting the plea bargain.

A. In November of 2004 Circuit Judge Robert Heard, acting as a private attorney, informed me that Oregon and one other state allowed for non-unanimous verdicts in criminal felony cases.

III. The undue duress placed on Defendant, a severely disabled person during incarceration, was a violation of his civil rights. Defendant seeks to have his 2005 judgement reversed.

A. Because of Defendant’s severe disabilities and the compromising position that confinement presented Defendant made the decision under duress to accept a plea bargain from the District Attorney of Washington County, Robert W. Hermnann. “One of the primary factors that led to this decision was based on defendant’s understanding that the District Attorney would only need ten out of twelve jurors to convict.

Pro Se Litigant


Washington County Courthouse — Criminal Court
145NE 2nd Avenue, Hillsboro, OR 97124

In the matter of,

1. I was born with a condition called Retnitus Pigmentosa and, at age fifty-nine, am completely 100% blind.

2. I am approximately 40% hearing impaired in my right ear, and approximately 30% hearing impaired in my left ear.

3. For the reasons described in the attached letter to the Multnomah County Court, I currently suffer from moderate to severe PTSD.

I swear under penalty of purgury that the following is
true, to the best of my knowledge.

Donald Ray Wolfe
Pro se litigant