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08-30-2016 ECF 1148 USA V SHAWNA COX - USA Stipulation To
08-30-2016 ECF 1148 USA V SHAWNA COX - USA Stipulation To
Document 1148
Filed 08/30/16
Page 1 of 2
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
Page 2 of 2
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
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