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Case 3:16-cr-00051-BR

Document 1159

Filed 08/31/16

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MATTHEW SCHINDLER, OSB# 964190


501 Fourth Street #324
Lake Oswego, OR 97034
Phone: (503) 699-7333
FAX: (503) 345-9372
e-mail: mattschindler@comcast.net
ATTORNEY FOR DEFENDANT KENNETH MEDENBACH

UNITED STATES DISTRICT COURT


DISTRICT OF OREGON
UNITED STATES OF AMERICA,
Plaintiff,

Case No. 3:16-CR-00051-16-BR


MOTION FOR ORDER
MODIFYING CONDITIONS OF
PRETRIAL RELEASE

vs.

KENNETH MEDENBACH,
Defendant(s).
Defendant, Kenneth Medenbach, through standby counsel, Matthew
Schindler, moves the Court for an order removing the GPS location monitoring and
House Arrest from his special conditions of his release. He also requests the Court
remove the portion of the no-contact provision that restricts him from any contact
with miltias.
Mr. Medenbach has conferred with the government and it has no objection
to the elimination of the above conditions.
Since Mr. Medenbach was released by the court on July 15, 2016 he has been
in compliance with all conditions of his pretrial release. He has attended all court

Page 1 MOTION FOR ORDER MODIFYING CONDITIONS OF PRETRIAL RELEASE

Case 3:16-cr-00051-BR

Document 1159

Filed 08/31/16

Page 2 of 2

hearings as directed including those in Eugene, Oregon. He has respected and


complied with the orders of the court. At a show cause hearing, August 30th, 2016
under questioning from the court about his continued pro se status, Mr. Medenbach
repeatedly assured the court that he would not raise inappropriate issues before the
jury. The court accepted those assurances and allowed him to continue pro se.
There does not appear to be any ongoing concern that he will not comply
with the orders of the court. Trial in this matter begins September 7 and continued
ankle monitoring and house arrest will unnecessarily interfere with Mr.
Medenbachs ability to prepare for representing himself at this trial.
The no contact provision regarding militias is too vague to be enforceable.
Furthermore, it restricts Mr. Medenbachs associational rights in a way that does not
further reasonable objectives of pretrial release. It should be removed.
Mr. Medenbach respectfully requests the Court enter an order modifying the
conditions of his pretrial release as outlined above.

Respectfully submitted on August 31, 2016.

Matthew A. Schindler, OSB#964190


Hybrid counsel for Kenneth Medenbach

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