Gerald M. Needham, OSB # 96374

Assistant Federal Public Defender

101 SW Main Street, Suite 1700

Portland, OR 97204-3228

Tel: (503) 326-2123

Fax: (503) 326-5524

jerry_needham@fd.org

Attorney for Defendant

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF OREGON

PORTLAND DIVISION

UNITED STATES OF AMERICA,

Plaintiff,

v.

JASON MICHAEL KEATING,

Defendant

Case No. 3:14-cr-00282-KI

AFFIDAVIT OF COUNSEL IN 

SUPPORT OF UNOPPOSED MOTION 

TO CONTINUE TRIAL DATE

STATE OF OREGON )

) ss:

County of Multnomah)

I, Gerald M. Needham, being duly sworn, do depose and say:

1. I am counsel for Jason Michael Keating in the above-entitled action.

2. Mr. Keating has been indicted for one count of Conspiracy To Transport, Receive, And 

Sell Stolen Goods in violation of 18 U.S.C. §371, and one count of Receipt Of Stolen 

Goods in violation of 18 U.S.C. §2315. The indictment contains a forfeiture allegation.

3. December 9, 2014, is the second trial setting.

PAGE 1. AFFIDAVIT OF COUNSEL IN SUPPORT OF UNOPPOSED MOTION TO CONTINUE TRIAL 

DATE

Case 3:14-cr-00282-SI Document 34 Filed 12/01/14 Page 1 of 3
4. Mr. Keating has been released on pretrial conditions. He remains in compliance with all 

aspects of his release conditions. Counsel has spoken with Mr. Keating concerning the need 

for a continuance. He authorized counsel to represent he consents to a continuance of his 

trial date with the knowledge that the timeframe is excludable under the Speedy Trial Act 

pursuant to 18 U.S.C. §3161(h)(7)(A).

5. Counsel has received discovery materials. Additional time is required to review discovery 

materials, conduct pretrial investigation, consult with Mr. Keating, and otherwise properly 

prepare for trial.

6. An additional issue has arisen concerning the restitution amount. Defense counsel is in 

need of additional time to conduct legal research concerning this issue. 

7. Assistant United States Attorney Ryan Bounds has authorized counsel to represent the 

government has no objection. 

8. Mark Cogan, counsel for co-defendant Tung Wing Ho, has moved to continue the trial 

approximately 90 days.

9. Based on the aforementioned, counsel moves to continue the trial of December 9, 2014, to 

March 10, 2015, or a date thereafter convenient to the Court. The timeframe of the 

requested continuance is excludable from Speedy Trial computations pursuant to 18 U.S.C. 

§3161(h)(7)(A), as additional time is required for pretrial investigation and trial preparation 

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PAGE 2. AFFIDAVIT OF COUNSEL IN SUPPORT OF UNOPPOSED MOTION TO CONTINUE TRIAL 

DATE

Case 3:14-cr-00282-SI Document 34 Filed 12/01/14 Page 2 of 3
and the ends of justice served by the granting of the continuance outweigh the interests of 

the public and the defendant in a speedier trial.

DATED this 1st day of December, 2014.

/s/ Gerald M. Needham

Gerald M. Needham

Attorney for Defendant

SUBSCRIBED AND SWORN to before me this 1st day of December, 2014.

/s/ Jennifer Louise Lillie

Notary Public for Oregon

My commission expires: 3/22/2017

PAGE 3. AFFIDAVIT OF COUNSEL IN SUPPORT OF UNOPPOSED MOTION TO CONTINUE TRIAL 

DATE

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