Case 3:16-cr-00051-BR

Document 1488

Filed 10/25/16

Page 1 of 3

Jason Patrick, Pro Se

c/o Andrew M. Kohlmetz, OSB #955418
Kohlmetz Steen & Hanrahan PC
741 SW Lincoln Street
Portland, OR 97201
Tel: (503) 224-1104
Fax: (503) 224-9417
Email: andy@kshlawyers.com

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF OREGON
PORTLAND DIVISION

UNITED STATES OF AMERICA,

Plaintiff,
vs.
JASON PATRICK,
Defendant

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Case No. 3:16-CR-00051-BR-09

DEFENDANTS MOTION TO AMEND
CONDITIONS OF RELEASE
(ORAL ARGUMENT REQUESTED)

COMES NOW Defendant, Jason Patrick, and hereby moves the Court pursuant to 18
U.S.C. 3145(a)(2) for an Order amending the conditions of his release in the following
particulars.
a. Removal of the travel restrictions on the defendant as unnecessary and overly
restrictive.
b. Removal of the drug and alcohol testing conditions as unnecessary and overly
restrictive.
c. Removal of the condition that he not associate with militia member, as that term lacks
sufficient definition/precision to allow the defendant to ensure compliance therewith.

DEFENDANTS MOTION TO AMEND RELEASE CONDITIONS

Kohlmetz Steen & Hanrahan PC
741 SW Lincoln Street
Portland, OR 97201
(503) 224-1104

Case 3:16-cr-00051-BR

Document 1488

Filed 10/25/16

Page 2 of 3

The defendant was released upon conditions by Order of this Court on July 12, 2016.
Since that time he has been regularly reporting to United States Pretrial Services and has
been faithfully attending the trial proceedings currently being held in this matter. In the
approximately one hundred days since Mr. Patricks release upon conditions, no
violations of those conditions have been reported. In light of the recent storm and
flooding disasters in Louisiana and the Eastern seaboard, Mr. Patrick would like to be
able to travel, as he has in the past, to assist those who have been displaced by natural
disasters. His skills in carpentry, general contracting and roofing are valuable assets to be
brought to bear in such circumstances and he is willing to volunteer his time as needed.
Mt. Patricks children also reside on the East Coast and he would very much like to visit
with them if able.
There have been no violations related to any use of alcohol and controlled
substances and the continued testing for such is not called for. Furthermore, Mr. Patrick,
who is indigent, is often in Portland attending trial and or meeting with standby counsel
or other parties to the case. When randomly selected for testing he must physically
present himself to the U.S. Pretrial services office in Seattle, Washington. Mr. Patrick has
no car and must rely on the kindness of others to transport him back and forth from
Seattle to Portland, or his residence in Mukilteo, Washington.
Mr. Patrick indicates that both he and his supervising officer have questions about
the term militia members. Neither understand what that term means beyond someone
who might self-identify as a militia-member. Mr. Patrick is concerned that in meeting
with and discussing his case with other protesters he may come into contact with a person
or person the government believes is a militia-member but who denies the same.
DEFENDANTS MOTION TO AMEND RELEASE CONDITIONS
Kohlmetz Steen & Hanrahan PC
741 SW Lincoln Street
Portland, OR 97201
(503) 224-1104

Case 3:16-cr-00051-BR

Document 1488

Filed 10/25/16

Page 3 of 3

Respectfully submitted this 25th day of October, 2016.

/s/ Jason Patrick
________________________________
Jason Patrick, Pro Se

DEFENDANTS MOTION TO AMEND RELEASE CONDITIONS

Kohlmetz Steen & Hanrahan PC
741 SW Lincoln Street
Portland, OR 97201
(503) 224-1104