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Case 3:16-cr-00051-BR

Document 1250

Filed 09/12/16

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Tiffany A. Harris OSB 02318


Attorney at Law
333 SW Taylor St., Suite 300
Portland, Oregon 97204
t. 503.782.4788
tiff@harrisdefense.com
Attorney for Defendant Shawna Cox

UNITED STATES DISTRICT COURT


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

3:16-CR-00051-BR-6
DECLARATION OF COUNSEL
REGARDING CERTIFICATION
OF CONFERRAL

Defendant.

I, Tiffany A. Harris, declare the following to be true to the best of my knowledge:


1.

I was appointed to represent Ms. Cox in January of 2016, after she was arrested

in connection with the protests staged in Harney County and the Malheur National Wildlife
Refuge. She made her first appearance on January 29, 2016 and was released on conditions.
The Government obtained a superseding indictment on March 8, 2016. Ms. Cox is now charged
with Conspiracy to Impede Officers of the United States under 18 USC 372 and Possession of
Firearms and Dangerous Weapons in a Federal Facility under 18 USC 930(b).
2.

On July 18, 2016, Ms. Cox assumed the duties of self-representation.

3.

Since that time, I have assisted with the electronic filing of motions drafted and

submitted to the Court by Ms. Cox in her pro se capacity. I have also facilitated conferral with

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


Declaration of Counsel in Regarding Certification of Conferral

Case 3:16-cr-00051-BR

Document 1250

Filed 09/12/16

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the Government so that the parties positions on Ms. Coxs motions could be represented to the
Court.
4.

I have alerted the Government to the filing of docket no. 1249, in which Ms. Cox

asks the Court to reconsider its order (docket no. 1228) denying Ammon Bundys Motion to
Dismiss for Lack of Subject Matter Jurisdiction (docket no. 1155). Based on my training and
experience, I believe the Government will oppose the motion. Because all of the parties are,
without a doubt, preparing for tomorrows opening statements, I do not believe the Government
will have an opportunity, before tomorrow, to confer with me and confirm its likely opposition to
the motion. However, in the interest of judicial efficiency, I believe it is appropriate to file this
motion before, rather than during trial.
5.

Under the circumstances, I ask the Court to accept M. Coxs filing on the

condition that Ms. Cox and or standby counsel confirm the Governments position tomorrow,
before the proceedings begin or at such other time as the Court deems appropriate.
I declare under penalty of perjury that the forgoing is correct to the best of my knowledge
and belief.

Respectfully submitted on September 12, 2016


/S/
Tiffany Harris
Tiffany A. Harris, Attorney at Law
Standby Counsel for Defendant Shawna Cox

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


Declaration of Counsel in Regarding Certification of Conferral