An Outsider - A Change of Venue

Brookings, Oregon is the Wild Wild West where buyer, you have no protections and the #CityCouncil refuses to pass even the most standard statutes, like an outdoor light statute to protect innocent home purchasers who buy in an environment where local realtors are protected.

Change of Venue

Upon filing my lawsuit, I concurrently requested a #ChangeofVenue due to the overwhelming bias I faced in Brookings, Oregon, a town of 6,500 residents. This bias stemmed largely from multiple social media posts made by Tiffany and Trenton, whose combined 3,500 followers had posted 2,596 likes and 189 derogatory comments about me. Tiffany painted me as “crazy” (using the term “cray, cray”) and falsely accused me of committing tax fraud, among other things. #JudgeStone denied my initial request, and after presenting new evidence, I filed another motion to change the venue, which was again denied. Some of the comments made by the #Bergs’ followers include: "F*ckin move then, " “She needs to be in an institution," "This woman sounds psychotic – she needs mental help," and "Looney tunes music plays".

Additional reasons for my request include:

1.     I have a list of Tiffany’s 2,500 Facebook friends who could potentially serve on a jury. Yet, I won’t receive the jurors’ names until the trial day, which leave me with no way to investigate possible connections between jurors and the Bergs’, where almost half could be friends or associates with them in the small town. The Bergs are a well-established family in Brookings, while I am an outsider.

2.     Judge Martin Stone, who has shown extreme bias against outsiders, rewarded Tiffany for deletin her #TikTok account by refusing to issue a sanction against her and instead allowing her to go to court with her well-connected attorney to make up her own unproven facts and allegations - a he said/she said scenario since he ruled against discovery from Google based on their incorrect assertion of the law. One does not need to get a California's court to serve a subpoena on them from an #Oregon court. When I requested sanctions against Tiffany since I should have to subpoena TikTok and #Goole and judge Stone denied my request - rewarding Tiffany for deleting the evidence for my case.

3.     #JudgeMartinStone is allowing an expert to come into my home without allowing me the credentials and the equipment they will use, which is my constitutional right to unlawful search and seizure and more. If someone is coming in your home to testify, then they must reveal their credentials and the equipment they intend to use. You shouldn't have to wait for them to be on the stand in a courtroom. This is unlawful and a violation of the fourteenth amendment.

4. When Tiffany flew a drone directly at me while I was standing on my property, about fifty feet from the property line next to my shed on June 18, 2025, the Brookings police did nothing. They told me it was fine, even though the FAA confirmed the Bergs’ drone was unregistered—illegal. Evidence obtained from the city shows a photo Tiffany took from her drone of the inside of my shed, where I have an expectation of privacy. Imagine living next door to someone like that. According to Oregon law, it is illegal to fly a drone over a neighbor to harass. If this isn't harassment, then what is? Yet, the police did nothing in their pattern of protecting Tiffany no matter what.
   

5. In Gold Beach, the Sheriff ignored my service request for over six weeks, causing me to pay five times the normal cost to hire a process server from Medford, OR.
   

6. I made two presentations to the City Council and Planning Commission asking them to pass an outdoor light statute like other remote towns in Oregon and California. Yet, they refused to even consider this simple statute.

7. The Bergs repeatedly blasted my 2023 City Council presentation over their outdoor speaker late into the night on multiple occasions in October of 2023< June 18, 22, 23, 24, 25, 26, and July 1, 3, 5, 10. Despite me calling the police over seven times, they took no action, forcing me to have to personally cite Tiffany. Police Chief Kelby McCrae sent an email stating that Tiffany could play my presentation anywhere, anytime, even after I complained.

From: #KelbyMcCrae [mailto:mccraek@brookings.or.us]Sent: Monday, July 1, 2024 4:51 PMTo: Lauri ZiemerCc: Tony BaronSubject: Re: FW: Tuesday Presentation

Lauri,

Has anyone else made a complaint about Tiffany's light?  Also, on Cheryl's complaint about Tiffany showing Cheryl in a public meeting, there's nothing wrong with that.  It was a public meeting and it is free to replay the public recording anywhere you like for as long as you like.  Let Cheryl know it's also on YouTube.

Chief Kelby McCrae

Brookings Police Department

898 Elk Drive

Brookings, OR  97415

mccraek@brookings.or.us

(541) 469-3118 x2200

8. In Municipal court, #JudgeMilliman prevented me from presenting all of my evidence, which had been submitted in advance, and disallowed my witness from offering important context about Tiffany's harassment. Meanwhile, Tiffany was allowed to ramble on with unproven and irrelevant facts. When found guilty, Tiffany was only fined $100—a trivial penalty, despite me spending $1,500 to attend the trial in Brookings.
   

9. After an officer recommended the Brookings District Attorney be informed of abusive behavior by the Bergs' children, who called me derogatory names, the DA took no action.
   

10. The #CurryCounty court does not accept or store video evidence. Since this case involves defamation on TikTok and YouTube—both consisting of videos—the court is simply not modern enough for me to receive a fair trial, which is my constitutional right.
    

11. #LaurieZiemer of the City of Brookings echoed the city's dismissive attitude regarding my light complaint, asserting that since the neighbors above the Bergs hadn't complained about the light, my claim must be false. But those neighbors are over 200 feet away, and their property isn’t impacted by the light in the same way mine is. The light is only 15 feet from my property line, like placing a light at the apex of a bowl.

    
    

    

    
    

12. The City of Brookings is named in the lawsuit for drainage and the septic.

    
    

13. After I placed an ad in the local newspaper, the Pilot, asking for support for an outdoor light statute—without ever personally attacking the Bergs—I was told I could not advertise again. What a reaction!
    

14. I went to the #ElksClub with fliers seeking support for the outdoor light issue. At Council member #ClaytonMalmerg’s table, a woman demonstrated clear hostility. When I asked her why, she invited me outside to yell at me with comments like, “You made a comment that the Planning Commission was all male, and those men have wives.” She wouldn’t even listen when Cheryl tried to discuss the light issue.

    

    
    

15. It is common in Oregon to harbor animosity toward people moving from California. I am from Warren, Michigan, and I have experienced bias against outsiders. Media outlets like the LA Times have documented this trend. Tiffany's social media followers have also expressed this disdain.

a.     Are Californians really all fleeing to Oregon? Here's what the data shows": This article from the Salem Statesman Journal discusses migration patterns, noting that 4.36% of California's moves in 2023 were to Oregon. Are Californians all moving to Oregon? What the data shows 

b.     When Californians Move to Oregon, They're More Likely to Move to the Coast": Willamette Week highlights a study by state economist Josh Lehner, indicating that Californians relocating to Oregon often choose coastal regions, central, and southern areas. https://www.wweek.com/news/2019/07/13/when-californians-move-to-oregon-theyre-more-likely-to-move-to-the-coast/?utm_source=chatgpt.com

c.     Californication": This Wikipedia entry explores the term "Californication," which criticizes California-style urban sprawl and reflects sentiments in states like Oregon regarding the influx of Californians. https://en.wikipedia.org/wiki/Californication_%28word%29?utm_source=chatgpt.com

d.     Why Californians REGRET Moving to Oregon | Top Reasons": A YouTube video discussing common regrets Californians may have after relocating to Oregon, shedding light on potential cultural clashes and expectations. Why Californians REGRET Moving to Oregon | Top Reasons

16. Judge Stone, who was initially elected, demonstrated extreme bias against me by removing my motion from the calendar in favor of the Bergs, later reversing his decision. He ignored the law regarding my discovery request from Goo\gle, wrongly claiming I didn’t follow the correct protocol when it was, in fact, he who misunderstood the law.

    
    

17. Judge Stone denied my request for sanctions against Tiffany deleting her original TikTok account for which my complaint is based, which is called evidence spoilage, and rewarded her for this act by placing me in a position of facing a he said/she said scenario in biased Brookings. What a joke! She recently created a new account. I made a report to the Oregon Attorney General. So, we'll see. How well connected is this ex-prison guard?

    
    

18. Judge Stone manipulated the scheduling of cases expecting me to argue my Summary Judgement and more when it wasn't even scheduled on that day.

    
    

19. Tiffany falsely accused me of installing an illegal septic system, which I did not do, claiming I avoided paying for a permit by doing it myself. She also claims I’m "drunk as a skunk" every night, which is simply not true. I’ve never been drunk in Brookings, Oregon, and my landlord in Santa Barbara attested that he has never seen me intoxicated during our year of rental. Tiffany just fabricates these stories. This is exhausting. See my blog named False Allegations for the evidence of yet another false allegation by Tiffany Berg.

    
    

20. The extreme defamation against me by the Bergs' using the TikTok account Tiffany deleted when sued. See my blog called Defamation.

    
    

21. #AnthonyBaron from the city Planning Commission called my presentation to them as bullying tactics. What bullying tactics. I begged them to pass an outdoor light statute so I would not have to litigate. I never threatened legal action. This is elderly abuse at this point This man who doesn't work for the city interjects into what is not his business and states in an email 'have the police gone buy to see where she is sleeping. Well, if the police are coming onto my p roperty, they better have a warrant to check up on me! Let's vote Anthony Baron off of any and all boards in Brookings!

    More important, this demonstrates how the small town is a good old boy - all connected.

    
    

Brookings is a small, close-knit town where the Bergs hold significant influence, with a Portland-based attorney paid for by their insurance. In contrast, I as a plaintiff in a real estate lawsuit, which buyers are the plaintiff in all real estate lawsuits 99.99% of the time, I must bear the costs upfront, which is a practice that enables dishonesty in real estate dealings.

In Oregon, both the U.S. and Oregon State Constitutions guarantee the right to a fair trial. The Sixth Amendment guarantees the right to a fair and public trial, and Article I, Section 11 of the Oregon Constitution ensures due process of law. Under ORS 144.110(1), a judge may grant a change of venue if extreme prejudice makes a fair trial impossible (see McDonnell v. Premo, 2021, and Praegitzer Industries v. Rollins Burdick Hunter, 1994). ORS 14.120 allows for a motion to change the trial venue at any time before the trial begins.