PAGE 1 – MEMORANDUM IN SUPPORT OF MOTION TO REVOKE PRETRIAL DETENTION 

ORDER

RAMÓN A. PAGÁN, OSB No. 103072

The Law Office of Ramón A. Pagán, LLC

249 NE Lincoln Avenue

Hillsboro, Oregon 97124

Telephone: (971) 270-0421

Facsimile: (866) 431-9948

Email: rpagan@outlook.com

Counsel for Corey Lequieu

IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF OREGON 

PORTLAND DIVISION

 

UNITED STATES of AMERICA, 

Plaintiff,

v.

COREY LEQUIEU, et al.,

Defendant.

____________________________________

Case No. 3:16-cr-00051 BR

MEMORANDUM IN SUPPORT OF 

MOTION TO REVOKE PRETRIAL 

DETENTION ORDER

Preliminary Statement

Defendant Corey Lequieu has been charged, by superseding indictment, with Conspiracy 

to Impede Officers of the United States in violation of 18 U.S.C. § 372, Possession of Firearms 

and Dangerous Weapons in Federal Facilities in violation of 18 U.S.C. § 930(b), and Use and 

Carry of a Firearm in Relation to a Crime of Violence in violation of 18 U.S.C. § 924(c)(1)(A). 

Mr. Lequieu was arrested in Nevada on a separate, now-dismissed indictment 

(3:16cr00051(JO)), on or about February 11, 2016. In Nevada, the district court ordered his 

detention and he was transported to the District of Oregon.

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ORDER

Mr. Lequieu first appeared before this Court on the previous indictment on February 22,

2016. Magistrate Judge Stewart issued an order of detention on February 22, 2016. I was 

appointed as his counsel pursuant to the Criminal Justice Act.

Mr. Lequieu poses no danger to the community and he is not a flight risk. He has a home 

in Fallon, Nevada to return to and he is adamant in his desire to appear and defend himself, along 

with his co-defendants, at trial. Mr. Lequieu has the support of his community and his fiancé, 

Ms. Deborah Carter Pope, with whom he will reside in Fallon, Nevada, if released.

Defendant’s Plan for Release

If released, Mr. Lequieu would return to his home in Fallon, Nevada with his fiancé, Ms. 

Pope. We have contacted his prior employer, Jim Chambers, who has informed us that Mr. 

Lequieu would be re-hired if he returned to his community. Mr. Lequieu is a combat-veteran of 

the United States Army, has never had any mental health issues, and any criminal convictions he 

has are far in his past. As the Court is now well aware, all of the defendants in this case are 

enthusiastic to appear and defend themselves. Mr. Lequieu is no exception. He has a strong 

desire to have his day in court, and he would be focused on assisting his defense team with trial 

preparation. 

18 U.S.C. § 3142

Under the Bail Reform Act, 18 U.S.C. § 3142, any person charged with an offense

under the federal criminal laws shall be released pending trial: (a) on personal

recognizance; (b) upon execution of an unsecured appearance bond; or (c) on a condition

or combination of conditions, unless a "judicial officer finds that no condition or

combination of conditions will reasonably assure the appearance of the person as required

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ORDER

and the safety of any other person and the community." 18 U.S.C. § 3142(e)(1); see also,

18 U.S.C. § 3142(a), (b). Under the Act, a court must impose the least restrictive

conditions to reasonably assure the appearance of the person as required and the safety of

any other person and the community. 18 U.S.C. § 3142(c)(1)(B). Further, an accused’s right to 

bail is constitutional in nature. See, e.g., U.S. v. Hir, 517 F.3d 1081, 1085-86 (9th Cir. 2008) 

(noting the constitutional rights associated with bail). 

18 U.S.C. § 3142(g) lists several factors a court must consider when deciding a motion 

for release, including: "the nature and circumstances of the offense charged"; "the weight of the

evidence against the person"; "the history and characteristics of the person," including,

inter alia, the person’s “character, physical and mental condition, family ties, employment,

financial resources, length of residence in the community, community ties, past conduct,

history relating to drug or alcohol abuse, criminal history, and record concerning

appearance at court proceedings"; and "the nature and seriousness of the danger to any

person or the community that would be posed by the person's release." 18 U.S.C. § 3142(g).

The government must show, by clear and convincing evidence, that there are no 

conditions or combination of conditions sufficient to ensure the defendant’s return or the public’s 

safety. 18 U.S.C. § 3142(f)(2). 

Here, the government may argue that the nature of the charges indicate that Mr. Lequieu 

is a danger to the community, but the allegations in the superseding indictment do not make out 

such a claim, and Mr. Lequieu’s criminal history, old as it is, should not be dispositive in a case 

such as this.

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ORDER

Background Information

Mr. Lequieu, 46 years old, grew up in California. Graduating high school at the age of 

16, he quickly entered the United States Army at the age of 17 in 1987. He served as an Army 

Ranger and was deployed to multiple foreign locations for combat. He served for 6 years, was 

never disciplined, and was honorably discharged in 1993. 

Following his service, Mr. Lequieu did suffer setbacks and eventually found himself in 

the criminal justice system. As the Court is aware from the pre-trial services report, in the mid1990’s, he was convicted of several offenses and spent significant time in a penitentiary. In 

2004, due to his prior record, he was again convicted and spent further time in a penitentiary. 

Since then, he has had much greater success avoiding the criminal justice system, suffering only 

minor parole violations and a failure to register violation in Nevada. 

After the dust has settled from those prior convictions, he met Deborah Carter Pope, with 

whom he has lived now for seven years. Ms. Pope is a former deputy sheriff in Fallon, and she 

served in the United States Air Force as well. Together, they have been parents to her son, 

Jeremiah Carter, who is graduating from the United States Marine Corps this month. Jeremiah 

considers Mr. Lequieu his father, and reveres him for his service and dedication to our nation.

Throughout his life after service, Mr. Lequieu has worked many different jobs. Over the 

last several years, he has worked for a man named Jim Chambers, who owns a hauling company

in Fallon, Nevada: Chambers Hauling. Mr. Chambers has indicated that he is eager to re-hire 

Mr. Lequieu should he be released pending trial. 

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Mr. Lequieu and Ms. Pope own a trailer together, and have lived at the same address for 

seven years. If released, Mr. Lequieu would return to that address and help Ms. Pope with 

expenses and her medical needs. 

18 U.S.C. § 3142(g) Factors

The Nature of the Offense

Now that the government has superseded the indictment, the allegations are plain: A 

group of protestors, some of whom were armed, overtook an empty federal facility. The 

government surely will argue that the nature of the offense dictates that detention is necessary, 

but the specific allegations, and the discovery in this case, do not bear that conclusion out. 

Notably, Mr. Lequieu is not mentioned as a leader of this group of protestors. He is not alleged 

to be an organizer or an inciter of this event. At no point was any government official alleged to 

have been directly confronted by Mr. Lequieu. At no point was any government official, or any 

community member, alleged to have been threatened by Mr. Lequieu. In the thousands of pages 

of discovery that have been turned over so far1

, there appears to be one witness who alleges that 

Mr. Lequieu even had a firearm on the refuge. Mr. Lequieu did not participate in, or create, any 

of the media releases or statements regarding the actions of the other protestors. Put simply, the 

broad-stroke allegation that the defendants in this indictment are all a danger to the community 

because they allegedly overtook this facility so deep in the heart of the Oregon high desert is 

specious, at best.

 1 It should be noted that counsel has not had an opportunity to view all of the discovery that has been produced 

because a large portion of it is being sorted and organized by the Federal Public Defender.

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ORDER

The History and Characteristics of the Defendant

Mr. Lequieu’s life has certainly had highs and lows. He would tell the Court that the 

highlight of his life was being able to serve his country as an Army Ranger. He would also tell 

the Court that his criminal convictions, and the life he lived around them, were certainly his 

nadir. It should be noted he does not have a history of absconding or failing to appear. But since 

that low time, he found Ms. Pope, and has been working and helping her with her family. He is 

notably not an activist, and though he is from Nevada, the Court should note he is not included in 

the Bundy Ranch indictment out of the District of Nevada. In fact, the protest in Burns may be 

the first instance of any activism he ever participated in. Were he to return home, he would get 

back to work, help his fiancé around the house with expenses and medical care, and he would 

focus on helping his counsel prepare his defense. 

The Nature of the Risk to the Public by the Defendant’s Release

There is no risk to the public if Mr. Lequieu is released. Even focusing on his criminal 

history, nearly all of his convictions involve property crime or possession of property for which 

he is barred from possessing. Otherwise, and particularly looking at the last ten years of his life, 

he is no threat to the public. Even looking at the allegations in this case, the government might 

concede that among all of the participants, Mr. Lequieu is alleged to be one with a very minor 

role. He is not alleged to have harassed any members of the public, and, in fact, according to 

documents from the government, he lived peacefully with residents of Burns before the alleged 

occupation. Besides the government’s argument about the danger of any group like these 

protestors, which can be debated by reasonable minds, Mr. Lequieu is not particularly dangerous 

and poses no special risk.

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ORDER

Conclusion

Because Mr. Lequieu has a solid plan for his release, and because he ostensibly poses no 

risk to the community, it is respectfully requested that his order of detention be revoked and an 

order of release be entered.

DATED this 16th day of April, 2016.

By:_s/RAP______________________________

Ramón A. Pagán, OSB No. 103072

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