Case 3:16-cr-00051-BR

Document 1122

Filed 08/29/16

Page 1 of 2

Tiffany A. Harris OSB 02318

Attorney at Law

333 SW Taylor St., Suite 300

Portland, Oregon 97204
Tel: (503) 782-4788
tiff@harrisdefense.com
Standby Counsel for Shawna Cox

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF OREGON
PORTLAND DIVISION
UNITED STATES OF AMERICA,
Plaintiff,
v.

3:16-CR-00051-BR-7
UNOPPOSED MOTION TO
ALLOW HYBRID COUNSEL
DURING JURY TRIAL

SHAWNA COX.
Defendant.

Shawna Cox, with the assistance of standby counsel, Tiffany A. Harris, moves the Court
for an order permitting a hybrid counsel arrangement during the course of the jury trial in this
case.
After a Faretta hearing and colloquy, the Court found that Ms. Cox made a knowing and
intelligent waiver of her right to court appointed counsel. Thereafter, counsel of record was
appointed in a standby capacity and Ms. Cox assumed the duties of self-representation.
In the months prior to the Faretta hearing, standby counsel had already retained certain
experts, located certain fact witnesses, and started work on certain pretrial motions (such as a
motion to suppress an eyewitness identification and a motion regarding the definition of
officers within the meaning of 18 U.S.C. 372.) Ms. Cox delegated additional, continued
work on these matters to Standby counsel so that they could be completed before trial.
USDC Oregon Case 3:16-CR-00051-BR
Unopposed Motion to Allow Hybrid Counsel During Jury Trial

Case 3:16-cr-00051-BR

Document 1122

Filed 08/29/16

Page 2 of 2

Ms. Cox now wishes to delegate certain other aspects of the trial preparation and jury
trial proceedings to standby counsel, and thus moves the Court for an order permitting a hybrid
arrangement at the jury trial. At trial, Ms. Cox elects to give the opening statement, conduct
certain of the cross examinations, conduct certain direct examinations, and give the closing
argument. Ms. Cox has delegated certain cross and direct examinations to standby counsel and
asks that standby counsel play a continuing role in providing advice and assistance upon request.
Should circumstances change, standby counsel will amend this motion as needed.
Ms. Cox understands that only one lawyer for each party may question a witness. She
has reviewed the courts trial conduct order, dated August 25, 2016.
The Government does not oppose this motion but asks that the Court conduct another
colloquy with Ms. Cox on the record, before an order is entered. The defense does not object to
further advisement of rights and responsibilities by the Court.

Respectfully submitted,
/S/
Tiffany Harris
Tiffany A. Harris
Standby Counsel for Defendant Shawna Cox
Reviewed and approved by
/S/
Shawna Cox
Shawna Cox
Pro Se Defendant

USDC Oregon Case 3:16-CR-00051-BR

Unopposed Motion to Allow Hybrid Counsel During Jury Trial