Case 3:16-cr-00051-BR

Document 1565

Filed 11/16/16

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BILLY J. WILLIAMS, OSB #901366

United States Attorney
District of Oregon
ETHAN D. KNIGHT, OSB #992984
GEOFFREY A. BARROW
CRAIG J. GABRIEL, OSB #012571
Assistant United States Attorneys
ethan.knight@usdoj.gov
geoffrey.barrow@usdoj.gov
craig.gabriel@usdoj.gov
1000 SW Third Ave., Suite 600
Portland, OR 97204-2902
Telephone: (503) 727-1000
Attorneys for United States of America

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON
UNITED STATES OF AMERICA

3:16-CR-00051-BR

v.
JASON PATRICK,
DUANE LEO EHMER,
DYLAN ANDERSON,
SEAN ANDERSON,
SANDRA LYNN ANDERSON,
DARRYL WILLIAM THORN, and
JAKE RYAN,

JOINT STATUS REPORT

REGARDING UPDATED
CASE-MANAGEMENT
PROPOSALS

Defendants.
Pursuant to the Courts November 1, 2016, Order (ECF No. 1527), attorneys for the
government have conferred with counsel for the above-named defendants, and the parties offer the
following suggested deadlines.

Case 3:16-cr-00051-BR

Document 1565

Filed 11/16/16

Page 2 of 2

Deadlines for Filing of Final Pretrial Motions and Responses

The parties propose filing any remaining pretrial motions, including motions in limine by
December 16, 2016, with responses due by January 6, 2017, and argument taking place during the
week of January 16.
Deadlines for Filing of Pretrial Documents and Responses
Defendants propose that pretrial documents (witness lists, exhibit lists, etc.) be filed by
January 20, 2017, to allow adequate time for objections and argument in the week preceding trial.
That will give the parties time to determine how long the trial will actually last in order to give the
jury an accurate prediction and avoid unnecessary cause excusals.
The government does not object to the filing of trial documents on January 20. It is the
governments position that the defendants responses should be due on February 4, 2017.
Deadline for Issuing Juror Summonses
Defendants position is that the summonses have to go out as soon as possible, and they
request 2000 summonses be issued.
The government requests that the issuance of the summonses be delayed while the
government evaluates its position regarding the February defendants. The government defers to
the Court on the number of summonses to issue.
Respectfully submitted this 16th day of November 2016.
BILLY J. WILLIAMS
United States Attorney
s/ Ethan D. Knight
ETHAN D. KNIGHT, OSB #992984
GEOFFREY A. BARROW
CRAIG J. GABRIEL, OSB #012571
Assistant United States Attorneys
Joint Status Report Regarding Updated Case-Management Proposals
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