IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF OREGON

UNITED STATES OF AMERICA, Case No. 3:14-CR-00267-BR

Plaintiff, CRIMINAL CASE 

MANAGEMENT ORDER 

v.

FABIAN SANDOVAL-RAMOS (D-1),

RAUL ARCILA (D-3),

SHANE GLEN BAKER (D-4),

MORGAN ELIZABETH GODVIN (D-6),

Defendants.

S. Amanda Marshall

United States Attorney

Leah Bolstad

Assistant United States Attorney

1000 SW Third Avenue, Suite 600

Portland, OR 97204

(503) 727-1000

Attorneys for Plaintiff

Steven T. Wax

Federal Public Defender

Patrick J. Ehlers

Assistant Federal Public Defender

101 SW Main Street, Suite 1700

Portland, OR 97204

(503) 326-2123

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Attorneys for Defendant-1

Todd E. Bofferding

1215 B Street

P.O. Box 539

Hood River, OR 97031

(541) 386-7924 

Attorney for Defendant-3

Bear Wilner-Nugent

620 SW 5th Avenue

Suite 1008

Portland, OR 97204

(503) 351-2327 

Attorney for Defendant-4

Russell Sterling Barnett , III

1500 SW 1st Avenue

Suite 780

Portland, OR 97201

(503) 946-8000 

Attorney for Defendant-5

BROWN, Judge.

Unless otherwise ordered by the Court, the parties shall comply with the following requirements

when requesting a continuance of the trial date and submitting trial documents.

1. Motions to Continue: Any motion to continue trial must be in writing and submitted no later 

than Noon on the Tuesday before the existing trial date. The Motion shall be accompanied by:

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a. An affidavit or other source of evidence from which the Court may make factual

findings sufficient under the Speedy Trial Act to allow a continuance, including

but not limited to:

(1) The calendaring history of the case, including the number of previous

continuances, and a computation of the time remaining under the Speedy

Trial Act calculated from the filing of the charging instrument or

Defendant's first appearance, whichever is later;

(2) The reasons a continuance is necessary, stated with sufficient specificity

1

 to permit the Court to make findings concerning both the necessity for

and the extent of a continuance; 

(3) The facts from which the Court may conclude the moving Defendant

understands the rights provided by the Speedy Trial Act but agrees with

the proposed continuance for the purposes stated and the extent

requested;

(4) The positions of all other parties concerning the proposed continuance; 

and

(5) A calculation of the time the moving Defendant has been in custody

solely because the Defendant is awaiting trial (18 U.S.C. § 3164(c)).

2. Trial Documents

a. Seven (7) days prior to trial, the parties shall simultaneously file the following

pretrial documents:

1

 If necessary to prevent disclosure of work product or other privileged material, a party may

submit an additional affidavit under seal setting out the facts that warrant a continuance.

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(1) all motions in limine:

(2) trial memoranda;

(3) proposed jury instructions following Ninth Circuit Model Jury

Instructions when possible (parties shall submit a complete set of jury

instructions, in plain text or rich text format (WordPerfect compatible) as

an attachment to an email message sent to the Judge's Courtroom Deputy

Clerk immediately following the electronic filing of the propose

instructions (see LR 51-1(d)(2));

(4) proposed form of verdict;

(5) proposed voir dire questions;

(6) exhibit lists; and

(7) witness lists, including summaries of any expert testimony.

b. Four (4)-days prior to trial, by 3:00 P.M., any responses to the above

documents shall be filed. 

IT IS SO ORDERED.

DATED this August 29, 2014.

 /s/ Anna J. Brown 

ANNA J. BROWN

United States District Judge

Courtroom Deputy:

Bonnie Boyer

Phone: (503) 326-8053

Email: bonnie_boyer@ord.uscourts.gov

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