PAGE 1. JOINT STATUS REPORT REGARDING DISCOVERY ISSUES SUBMITTED IN ADVANCE 

OF JUNE 15, 2016, STATUS CONFERENCE

Amy Baggio, OSB #011920

amy@baggiolaw.com

Baggio Law

621 SW Morrison, Suite 1025

Portland, OR 97205

Tel: (503) 222-9830

Fax: (503) 274-8575

Attorney for Defendant O’Shaughnessy

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF OREGON

PORTLAND DIVISION

UNITED STATES OF AMERICA,

Plaintiff,

v.

AMMON BUNDY, JON RITZHEIMER,

JOSEPH O’SHAUGHNESSY, RYAN 

PAYNE, RYAN BUNDY, BRIAN 

CAVALIER, SHAWNA COX, PETER 

SANTILLI, JASON PATRICK, DUANE 

LEO EHMER, DYLAN ANDERSON,

SEAN ANDERSON, DAVID LEE FRY,

JEFF WAYNE BANTA, SANDRA LYNN 

PFEIFER ANDERSON, KENNETH 

MEDENBACH, BLAINE COOPER, 

WESLEY KJAR, COREY LEQUIEU, 

NEIL WAMPLER, JASON CHARLES 

BLOMGREN, DARRYL WILLIAM 

THORN, GEOFFREY STANEK, TRAVIS 

COX, ERIC LEE FLORES, and JAKE 

RYAN

Defendants.

Case No. 3:16-cr-00051-BR

JOINT STATUS REPORT 

REGARDING DISCOVERY 

ISSUES SUBMITTED IN 

ADVANCE OF JUNE 15, 2016, 

STATUS CONFERENCE 

Case 3:16-cr-00051-BR Document 699 Filed 06/14/16 Page 1 of 16
PAGE 2. JOINT STATUS REPORT REGARDING DISCOVERY ISSUES SUBMITTED IN ADVANCE 

OF JUNE 15, 2016, STATUS CONFERENCE

The defendants, through Amy Baggio, and the government, through Assistant United 

States Attorney (AUSA) Geoffrey A. Barrow, submit the following Joint Status Report 

Regarding Discovery Issues Submitted In Advance Of June 15, 2016, Status Conference, as 

directed in the Court’s Order of June 13, 2016. (Doc. 673.) 

CERTIFICATION OF CONFERRAL: Undersigned counsel certifies that AUSA 

Geoffrey Barrow was provided a copy of, and consulted regarding the content of, this Joint 

Status Report. Both the defense and government positions are set forth below. 

A. Introduction

The above-captioned case presents unique challenges for the parties and the Court. 

Counsel for defendants have made best efforts to efficiently review discovery produced by the 

government so as to be prepared to meet the Court’s deadlines and adequately prepare the 

defense cases for trial. With this filing, the parties hope to provide the Court with a list of both 

the disputed discovery issues as well as the non-disputed, but yet to be provided, items of 

discovery. The parties hope that this list assists the Court in addressing these issues at the Status 

Conference on Wednesday, June 15, 2016. 

As of the June 12, 2016, the government had produced 38 volumes of discovery, all of 

which, with the exception of Volume 35, has been provided to all defendants. In addition to the 

volumes of discovery, the government has produced the contents of individual defendants’

Facebook pages directly to the individual defendants. The Facebook content provided to various 

defendants varies from 2,000 to 250,000 pages of material. The government has also made raw 

images of digital devices available to defendants with a privacy interest in those devices. To 

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PAGE 3. JOINT STATUS REPORT REGARDING DISCOVERY ISSUES SUBMITTED IN ADVANCE 

OF JUNE 15, 2016, STATUS CONFERENCE

date, only one defendant has asked for a copy of their digital device and arrangements have been 

made for that defendant. 

B. Contested Discovery Issues

In terms of seeking discovery beyond that provided by the government, the parties have 

engaged in a process in which defense counsel sends a request by letter or email to one of the 

three Assistant United States Attorneys (AUSAs). The AUSA then responds to the request to 

state whether the sought item(s) will be provided voluntarily, or whether the government objects 

to the request. The following chart is a best effort at delineating the various disputed discovery 

issues in need of Court intervention:

Contested Discovery Matters

Item Basis For Defense Request Government Position

Availability of all 

seized digital media to 

all defendants

The government states it will provide 

device images only to the defendant 

who has an expectation of privacy for 

that particular device; however, factual 

summaries state government intends to 

offer videos and other digital evidence 

obtained from one defendant’s digital 

device against other defendants. 

Accordingly, the devices or full FTK 

reports of those devices should be 

made available to all defendants.

Alternative defense position is that 

Government must review and disclose 

all such information as may be 

discoverable as (1) co-conspirator 

statements or acts in furtherance of the 

alleged conspiracy; (2) that have 

potential impeachment value--not only 

as to the named defendants but as to 

The government has produced and will 

continue to produce forensic copies of 

evidence seized pursuant to search 

warrants from digital devices. These 

forensic reports document all evidence 

the government seized and all evidence 

the government will use from these 

devices. These reports will be 

provided to all defendants.

Raw images of the devices necessarily 

contain data that was not responsive to 

the search warrants and, therefore, was 

not seized by the government. In some 

cases, the raw images may contain 

privileged information segregated by 

filter teams.

The government believes that 

production of the raw images to all 

defendants is improper. Through 

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OF JUNE 15, 2016, STATUS CONFERENCE

Item Basis For Defense Request Government Position

any prospective government witness, 

including a tendency to show that the 

content could create bias or hostility 

when reviewed by involved LE agents 

or agencies; and (3) that may 

otherwise be exculpatory, either as to 

guilt or punishment, e.g., tending to 

show role in the offense.

(Wood)

counsel, several defendants have 

alerted the government to their 

concerns regarding the distribution of 

non-responsive, private data from their 

digital devices. 

D. Nevada discovery 

provided to 

defendants not 

charged in Nevada 

case 

If the Government intends to introduce 

evidence of some defendants’

involvement in the Nevada stand-off 

during trial in this case, then 

defendants not charged in Nevada who 

are standing trial jointly with those 

defendants need access to the same 

discovery to, e.g., argue for cautionary 

instructions and otherwise prepare for 

likely “spill over” effect of that type of 

404(b) evidence against alleged coconspirators. In addition, if the Nevada 

discovery shows on-going 

relationships between Nevada 

defendants continuing through Refuge 

protest, and no affiliation with other, 

Oregon only defendants prior to the 

protest here, that information could 

lead to discovery of exculpatory 

evidence raising doubt about whether 

Oregon-only defendants are members 

of the same alleged conspiracy as the 

Nevada defendants. FRCP 16, 

disclosure of documents and other 

records material to the defense, and 

Brady. 

Alternative defense position is that 

Government must review and disclose 

The U.S. Attorney’s Office for the 

District of Nevada has asked that the 

government not disseminate the 

discovery to non-common defendants 

at this time.

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OF JUNE 15, 2016, STATUS CONFERENCE

Item Basis For Defense Request Government Position

all such information as may be 

discoverable as (1) co-conspirator 

statements or acts in furtherance of the 

alleged conspiracy; (2) that have 

potential impeachment value--not only 

as to the named defendants but as to 

any prospective government witness, 

including a tendency to show that the 

content could create bias or hostility 

when reviewed by involved LE agents 

or agencies; and (3) that may 

otherwise be exculpatory, either as to 

guilt or punishment, e.g., tending to 

show role in the offense.

(Wood & Baggio)

Large volume of 

email messages under 

review as of 5/18/16 

that Government 

believes will not be 

discoverable

Government needs to disclose the 

agencies and at least the positions 

(e.g., LE, PR, Admin) versus names of 

the authors and recipients of these 

emails, so that the defense has some 

information to make its own 

assessment of likely relevance and 

basis for discovery. Requests for 

discovery could then commence. 

(Wood)

The government is aware of its 

discovery obligations. It has produced 

and will continue to produce e-mail 

communications that are discoverable. 

There is no basis for the defendants’ 

request. 

Documents related to 

OIG investigation into 

1/26/16 vehicle stop 

of A. Bundy, R. 

Bundy, R. Payne, S. 

Cox, B. Cavalier & L. 

Finicum

The OIG investigation into the 

Finicum shooting and false statements 

to investigators is relevant and 

material to the defendants’ mental 

state, both before and after the 

Finicum shooting. Evidence about 

agents lying and covering up their 

actions is Brady. Mr. Olson intends to 

file a Motion to Compel these 

materials by end of day, 6/14/16. 

(Olson)

The government has produced 

materials related to the January 26, 

2016 arrest of Ammon Bundy, Brian 

Cavalier, Ryan Bundy, Ryan Payne, 

and Shawna Cox. 

The government will not call any law 

enforcement officers subject to the 

ongoing OIG investigation. The 

government does not believe that any 

additional information regarding the 

OIG investigation is discoverable in 

this case.

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OF JUNE 15, 2016, STATUS CONFERENCE

Item Basis For Defense Request Government Position

Information related to 

government’s display 

and use of force in 

response to the protest

Information regarding the 

government’s display and use of force, 

including snipers, bearcats, etc., 

should be provided as material to 

defense. Parties have conferred and 

will continue to confer, but Motion to 

Compel Production will most likely be 

filed on 6/14, including 18 

particularized requests and supporting 

Memorandum of law. (Wood)

The government does not believe that 

the defense is entitled to this 

information.

Information related to 

witness identifications 

practice & procedure

On May 27, 2016, counsel for Ms. 

Cox, on behalf of all defense counsel, 

sent the Government a letter 

requesting copies of all photographs 

used to elicit out-of-court 

identifications of our clients from 

witnesses interviewed by the FBI. The 

letter contained a non-exhaustive list 

of specific examples of interview 

reports that reference photographs that 

were reportedly shown to witnesses 

but never produced in discovery. The 

Government responded on June 13, 

2016, stating that certain photographs 

would be produced in the next round 

of discovery and certain photographs 

had not been retained by interviewing 

agents and were presumably lost or 

destroyed.

The defense requests a deadline of 

June 30, 2016, for the Government to 

search its files, locate photographs 

shown to witnesses and produce them 

in discovery. Although the 

Government has agreed to produce 

particular photographs identified by 

the defense and referenced in reports, 

we maintain that the Government has a 

duty to conduct its own 

The defense identified four instances in 

which witnesses were shown 

photographs that were not included in 

discovery. The government is 

producing the photographs from two of 

these interviews. Photographs from the 

two remaining interviews were not 

retained in the FBI file. Neither the 

defense nor the government has

identified any additional photographs 

that have not been produced in 

discovery. If any such photographs are 

identified, they will be produced in 

discovery. 

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OF JUNE 15, 2016, STATUS CONFERENCE

Item Basis For Defense Request Government Position

comprehensive search of its files and 

make a representation to the court that 

it has accounted for all photographs 

shown to witnesses, whether the 

corresponding 302 report mentions 

photographs or not. 

To the extent that the loss or 

destruction of photographs or the use 

of particular photographs may give 

rise to a motion to suppress, the 

defense requests additional time to file 

such motions given the timing and 

incomplete status of this discovery. 

(Harris)

Availability of all 

seized FaceBook 

content to all 

defendants

The Government intends to introduce 

content from the FaceBook accounts 

of various defendants to prove its case 

in chief. It is reasonable to assume that 

much of that FB content will refer to 

co-defendants and be offered under the 

co-conspirator HS exception. 

Defendants should be entitled to at 

least the seized FB content of those 

defendants ‘ accounts from which the 

government is selectively choosing its 

evidence. Rule 16 materiality, Brady. 

Alternative defense position is that 

Government must review and disclose 

all such FB content as may be 

discoverable as (1) co-conspirator 

statements or acts in furtherance of the 

alleged conspiracy; (2) that have 

potential impeachment value--not only 

as to the named defendants but as to 

any prospective government witness, 

including a tendency to show that the 

content could create bias or hostility 

when reviewed by involved LE agents 

or agencies; and (3) that may 

otherwise be exculpatory, either as to 

On May 16, 2016, prior to the 

completion of the search warrants, the 

government provided individual 

defendants with raw data that 

Facebook provided in response to the 

warrants. This information necessarily 

contains data that the government 

subsequently determined is not 

responsive to the search warrants and, 

therefore, has not been seized. In some 

cases, the raw images may contain 

privileged information segregated by 

filter teams.

The government has produced and will 

continue to produce forensic copies of 

evidence seized pursuant to search 

warrants from defendants’ Facebook 

accounts. These forensic reports 

document all evidence the government 

seized and all evidence the government 

will use from these accounts. These 

reports will be provided to all 

defendants.

The government believes that 

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Item Basis For Defense Request Government Position

guilt or punishment, e.g., tending to 

show role in the offense. (Wood)

production of the raw data to all 

defendants is improper. 

All information 

related to defendants’

Guardian files.

Discovery refers to the government’s 

reliance on information in the 

Guardian database both as a source for 

warrants and in its general discussion 

of investigating defendants and other 

individuals. The database is not to be 

used to gather information based on 

First Amendment-protected activity; 

however, references in discovery raise 

grave concerns that the government 

has done just that. 

Guardian and eGuardian go beyond 

collecting terrorism threat information. 

It is designed as a coordianted 

national, state and local law 

enforcement repository for the 

collection and analysis of any 

“...information that exhibits a 

reasonable suspicion of criminal 

activity” and what constitutes 

“possible criminal activity” is 

frighteningly broad: “a reasonable 

suspicion an activity constituting a 

federal crime...has or may have 

occurred, is or may be occurring, or 

will or may occur...”

The information may come from any 

source private or government. 

This collection and analysis implicates 

Fourth Amendment as well as First, 

according to OIG “Another privacy 

risk is the sum of the data entered into 

the eguardian system may be greater 

than its component parts, with the 

result that new and different 

information about incidents and 

people alleged to be suspicious 

The government has provided and will 

continue to provide discoverable 

information within the possession of 

the prosecution team, regardless of its 

source. 

The government is not aware of any 

specific request for information from a 

Guardian file or otherwise that has not 

been produced in discovery.

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Item Basis For Defense Request Government Position

becomes apparent.” (Kohlmetz)

Database collections 

on defendants and 

government 

witnesses, if relevant 

and material

Discovery refers to FBI use of a 

number of databases in investigating 

the defendants/subjects/witnesses. 

Defendants request production of their 

own files which are discoverable as 

giving rise to potential motions to 

suppress for monitoring based on First 

Amendment-protected activity as well 

as the explicit use of this information 

in seeking court orders. 

This evidence is also discoverable as 

to government witnesses if 

government witness files include 

impeachment evidence, such as 

evidence of pending investigations, 

suggestions of bias, or information 

related to truthfulness. (Kohlmetz) 

The government has provided and will 

continue to provide discoverable 

information within the possession of 

the prosecution team, regardless of its 

source. 

Non-Title III, FISA 

monitoring of 

communications

DOJ guidelines state that agents may 

monitor/record communications 

without a warrant and outside of Title 

III if a person lacks an expectation of 

privacy because any communication is 

not a “communication”, but 

defendants assert it is nevertheless a 

statement of the defendant 

discoverable under Rule 16 (Baggio)

The government has produced 

defendants’ statements pursuant to 

Rule 16(a)(1)(B). If any additional 

statements are identified, the 

government will produce them as 

required by Rule 16. 

Information regarding 

informants, 

undercover agents, 

agents-provocateurs

Discovery references use of informers 

and sources within media providing 

the government with information. 

Information as to these individuals has 

yet to be provided. In addition, 

defense seeks disclosure of use of 

undercover agents or agentsprovocateurs, both of which are 

discussed and encouraged in FBI 

manuals. Especially if agents incited 

targets to test their intent, or if they 

encouraged them to do anything 

The government will produce reports 

regarding information generated by 

confidential sources no later than July 

1, 2016. The government is not aware 

of any additional information that is 

subject to disclosure.

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Item Basis For Defense Request Government Position

related to the charges, this information 

is discoverable as Brady and materials 

to the defense. FRCP 16. (Baggio)

Propaganda Evidence suggests that the government 

used social media or traditional media 

to impact the public perception of the 

protesters and attempted to grab/own 

social media to counter/manipulate 

information about the protest. If so, 

this information is relevant and 

material to the defense both at trial and 

for purposes of jury selection/change 

of venue motions. (Baggio)

The government does not believe that 

defendants are entitled to any such 

information. 

C. Uncontested, But Unproduced Discovery

The government reports that it has substantially completed discovery to the defendants. 

However, certain items remain outstanding, the production of which may give rise to additional 

motions to suppress or motions to compel additional evidence. 

Uncontested, But Unproduced Discovery

Discovery Sought Defense Update On Status Government Update On Status

Reports on Digital 

Devices

Provided to DTI 6/8/16, but 

defendants having difficulty in 

accessing (see Ms. Wood’s 

statement, below)

The government has produced, or in 

the next batch of discovery will 

produce, forensic reports for nearly all 

of the devices. A few of the devices 

are being filtered for potentially 

privileged information. Five of the 

devices appear to be inaccessible. 

Images of Digital Media Not yet provided As set forth above, the government has 

offered to make raw images of 

defendants’ digital devices available to 

the defendants who have a privacy 

interest in the devices. To date, only 

one defendant has requested an image 

of their device.

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Geolocation Order Fruits 

(Ping Data)

Not yet provided (requested 6/8) The government is processing this data 

for an upcoming production and 

anticipates that it will available by the 

end of the week. 

Documents, 

correspondence regarding 

execution of Facebook 

search warrants

Not yet provided (requested on 

6/8/16)

On May 12, 2016, Facebook provided 

data in response to the warrant in 

Adobe .pdf format. As set forth above, 

the government sent defendants copies 

of their data on May 16, 2016. 

Facebook subsequently upgraded their 

internal procedures for complying with 

search warrants. On May 19, 2016, 

Facebook provided materials in an 

upgraded format. 

The government will provide raw data 

in the upgraded format to defendants 

who request it.

The protocols for executing the 

warrants are set forth in the affidavits 

and warrants previously produced in 

discovery.

Segregated Facebook 

seizures

Letter of 5/17/16 accompanying 

Facebook seizures for each 

individual defendant included 

statement that government was 

segregating seized data to what it 

believes is relevant to the case. 

None yet provided. 

As set forth above, the government is 

producing forensic reports from search 

warrants executed on Facebook 

accounts. The government anticipates 

that these reports will be produced 

within a week. 

Bruton statements Defendants seek production on 

July 11, 2016

Government asserts statements should 

be provided 10 days after the Court 

rules on defendants’ motions to 

sever/continue (which the government 

asks the Court to order both due on 

June 30, 2016)

404(b) Notice Parties agree information to be 

provided July 11, 2016

Parties agree information to be 

provided July 11, 2016

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D. Defendants’ Statement Regarding Impact Of Ongoing Discovery Issues

While the government has stated that discovery is substantially complete, that does not 

take into account very costly and time-consuming efforts defenders must now undertake to 

review the bulk of the discovery currently in hand, as discussed in more detail below. The 

government represents it will be disclosing much additional discovery between now and trial, see

Joint Discovery Status Report (5-18-2016) (Doc. 583). In addition, pending discovery requests 

(having either reached the stage of seeking Court intervention or still in the conferral process) are 

reasonably likely to result in substantial additional discovery. This combination of factors must 

be considered by the Court in reviewing the parties’ attempt to comply with its Order to identify 

discovery issues that may require future motion practice.

• The defense teams are unable to rely on the government discovery indexes to 

determine with needed precision what has been provided, because of the number of errors and 

omissions. The defense acknowledges the government is not obligated to provide an index, and 

even though incomplete and not free of errors, the indexes are of some value. The number of 

errors and omissions in this case is atypical of the US Attorney office, and most likely due to the 

government attempting to meet the goal of “substantial discovery completion” by mid-May. 

Regardless of the reason, this affects all defendants whether they are reviewing the discovery 

directly, or indirectly via DTI (Relativity). This is particularly troublesome for the more than 800 

video files that have been discovered. Social media and other video will be important to the 

government and defense cases, but the government indexes do not provide adequate information 

to allow an intelligent determination about whether to review or not review each video. 

Defenders’ best estimate is that it would require over 6000 hours to simply view all of these 

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videos, and that does not include any time to prepare notes or review selected passages in detail. 

Had the government provided detailed and accurate indexes, then many questions could have 

been answered without the need for time-consuming video review. 

• In addition, the government has provided 4,000-5,000 hours of raw video in 

proprietary formats that are difficult and slow to review. Many attorneys cannot review these 

videos at all because of the software required to view them, particularly those attorneys who use 

Apple computers. The government has the software and technology to provide computer-ready 

digital video files but did not do so. It will take hundreds of hours by some expert service 

provider and thousands of dollars to transcode this video into formats that defense teams can 

review. The same inadequate indexes mean defenders cannot make an intelligent determination 

about whether to review or not review each video. Accordingly, it would require roughly 5000 

hours to review these videos once transcoded.

• The government has provided over 13,000 photographs with few detailed 

descriptions in its indexes. DTI was unable to provide coding as to the date and time of the 

photographs. It will be up to the defense teams to review these photographs manually and extract 

metadata showing the dates and times.

• On June 9, 2016, defendants received 16 discs of complex Forensic Toolkit (FTK) 

reports of seized digital devices. None of this data will be uploaded in Relativity, and must be 

reviewed manually. FTK reports are particularly slow to review, and there are numerous native 

files in the form of photos and videos. None of the content of these reports was provided on an 

index from the government. This form of discovery is far more labor intensive to review than the 

Bates-stamped PDF pages that the government has supplied with their investigative reports. It is 

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anticipated that there will be additional digital device discovery, based on original estimates of 

up to 120-130 total digital devices seized by the government.

• Some of the defendants have received additional discovery of Facebook subpoena 

returns. Depending on individual defendant’s, this additional discovery varies from about 2,000 

to 250,000 pages, and is without Bates numbering. For some defendant, this single discovery 

item greatly exceeds the size of the total Bates stamped PDF discovery (see next paragraph), and 

was only received 3 weeks ago.

• There are just over 40,000 pages of PDF text files that are readily searchable by 

defense teams with their own software or with Relativity. This is a comparatively small amount 

of textual discovery for a complex case. It is the photographic, video, and digital device 

discovery that is staggering in its volume and corresponding time and cost to review. 

Review of 6000 hours of video, 13,000+ photographs, and up to 250,000 pages of 

Facebook subpoena returns , and the 16 discs of FTK digital device reports has barely begun. 

The 4,000 to 5,000 hours of raw video in proprietary formats from discovery has not 

commenced. Only the most basic review of the 40,000+ pages of FBI reports and other 

investigative documents has been completed. This is not due to any breach of discovery 

obligations by the government, nor to any lack of due diligence by defenders. It is simply the 

current state of discovery production and review in this complex case. It is not possible to make 

sound conclusions—and barely an educated guess—as to what new discovery issues, or 

substantive issues such as suppression, may arise, given this posture.

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F. Government’s Response

Defendants’ claim they cannot rely on the discovery indices the government has provided 

in this case due to unspecified errors and omissions. Until the exchange of the draft status report

on June 13, 2016, no member of the defense team has altered the government to any issue 

regarding the indices. On one occasion, the defense cited the government’s index to identify 

files that were inadvertently omitted from discovery. The promptly produced the missing files. 

The government’s discovery indices provide detailed information about the materials produced 

in this case. For the vast majority of the discovery materials, the indices include a detailed 

description of the item. For all materials, the indices provide the discovery volume and Bates 

number. While the discovery in this case includes many hours of videos, many generated by the 

defendants, that are not readily transferred to a discovery index, the discovery materials are well 

organized and described. If any member of the defense team has difficulty finding an item or 

alerts the government to a problem with an index, the government will work with them to rectify 

the issue.

Defendants complain about the formats of the video and photographs provided. Again, 

no member of the defense team alerted the government to any issues regarding the format of the 

materials until the exchange of the draft report. The government has provided photos and videos 

in native formats with metadata. The government is always available to help defendants with 

discovery. To suggest that the government failed to use available software or hardware or 

otherwise worked to thwart defendants’ access to the materials is inaccurate. 

Finally, defendants complain about the production of forensic reports of seized digital 

devices and Facebook materials. The Facebook raw materials have been provided in the same 

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format that the government received them. Forensic reports of the Facebook data are 

forthcoming. Forensic reports from digital devices have been produced in the same format that 

they are produced in virtually every criminal case in this district and throughout the country. 

Defendants’ suggestion that forensic reports could or should be indexed or Bates’ numbered 

ignores the very nature of the reports themselves. The addition of Bates numbers to a forensic 

report is not standard practice because it would alter the production of the data.

The government concedes that the volume of discovery provided poses challenges for the 

parties preparing for trial on an expedited basis. However, defendants’ suggestion that the 

manner of production has complicated the task is unsupported. The government will continue to 

work with the defense to facilitate their access to the discovery.

E. Conclusion

Undersigned counsel offers this Joint Status Report on behalf of defendants and the 

government. 

Respectfully submitted on June 14, 2016.

/s/ Amy Baggio

Amy Baggio, OSB #011920

503-222-9830

Attorney for Defendant O’Shaughnessy

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