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Case 3:16-cr-00051-BR

Document 1148

Filed 08/30/16

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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
3:16-CR-00051-BR-7

UNITED STATES OF AMERICA


v.
SHAWNA COX,

STIPULATION REGARDING MOTION


IN LIMINE TO EXCLUDE OTHER ACT
EVIDENCE (#1046)

Defendant.
The United States of America, by Billy J. Williams, United States Attorney for the
District of Oregon, and through Ethan D. Knight, Geoffrey A. Barrow, and Craig J. Gabriel,
Assistant United States Attorneys, and defendant Shawna Cox through her standby counsel,
Tiffany A. Harris, have reached the following stipulation with respect to defendant Coxs Motion
In Limine to Exclude Other Act Evidence (ECF No. 1046).

Case 3:16-cr-00051-BR

Document 1148

Filed 08/30/16

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Stipulation
At the time Shawna Cox was arrested, she had in her possession an SD card and two flash
drives.

These three electronic devices contained over 500 pages of official documents that were

scanned or downloaded from files on the Malheur National Wildlife Refuge, without the
permission of the Refuges employees.
Agreement Limiting Scope of Testimony on Direct Examination
The parties have reached an agreement that no government witness will testify at trial that
documents containing the locations of sacred Native American artifacts were stolen from the
Refuge or were unaccounted for after the occupation, unless a defense attorney or selfrepresented party makes such an inquiry on cross-examination.
Conclusion
Based on the above stipulation and agreement, the parties recommend that Shawna Coxs
Motion In Limine to Exclude Other Act Evidence (ECF No. 1046) be denied as moot.
Dated this 30th day of August 2016.
Respectfully submitted,
BILLY J. WILLIAMS
United States Attorney

s/ Craig J. Gabriel
ETHAN D. KNIGHT, OSB #992984
GEOFFREY A. BARROW
CRAIG J. GABRIEL, OSB #012571
Assistant United States Attorneys

Stipulation Regarding Motion In Limine to Exclude Other Act Evidence (#1046)

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