Case 3:16-cr-00051-BR

Document 1189

Filed 09/06/16

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FILED 6

SEP '16 E: ;S]USJC-ORP

IN THE UNITED STATES DISTRICT COURT FOR THE

DISTRICT OF OREGON
PORTLAND DIVISION

UNITED STATES OF AMERICA

Case No. 3:16-cr-00051-BR-7

Plaintiff;

v.

Shawna Cox

Defendant

MOTION TO DISMISS BASED ON

ENTRAPMENT

TO THE HONORABLE JUDGE OF SAID COURT:

COMES NOW the Defendant Shawna Cox the above entitled and numbered cause, and
requests this Honorable Court to dismiss the instant indictment based on grounds that the
Defendant was entrapped; and in support thereof would show the Court as follows:

I.
The instant indictment charges the Defendant with the offenses of 18 U.S.C. 372, 18 U.S.C.
930(b) and 2, 18 U.S.C. 924(c)(l)(A) and 2, and 18 U.S.C. 641 under United States Code,
entrapment is a defense from prosecution.

Case 3:16-cr-00051-BR

Document 1189

Filed 09/06/16

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11.
The Defendant engaged in the alleged conduct charged in the indictment solely because he was
induced to do so by a law enforcement agent using persuasion or other means was likely to
cause persons to commit the offenses. The conduct of the law enforcement agent went beyond
merely affording the Defendant an opportunity to commit the offenses alleged.

111.
The Defendant will make a prima facie case at a pre-trial hearing that she was entrapped in the
instant case. The United States Government will not be able to disprove this beyond a
reasonable doubt.
IV.
If the Government is unable to disprove the defense of entrapment beyond a reasonable doubt,
the remedy to be imposed by the trial court is dismissal of the indictment with prejudice.

WHEREFORE, PREMISES CONSIDERED, the Defendant respectfully prays that this

Honorable Court will grant this, the Defendant's Motion for Dismissal Based on Entrapment in
all things; or in the alternative, that this Court schedule this matter for a hearing prior to trial on
the merits and that at such hearing this Motion will be in all things granted.

Respectfully submitted,

Shawna Cox

Date

Case 3:16-cr-00051-BR

Document 1189

Verification
I certify the foregoing is true and correct under the
penalty of perjury pursuant to 28 USC 1746 that I
am over the age of 18 years, that I have personal
knowledge of the facts stated herein, and that I am
fu~nt to testify to those facts.

~.~
Shawna Cox Pro Se'

Certificate of Service
This the 31st day of August 2016 a true and correct copy
of the foregoing was served to the court, and opposing
counsel by first-class mail or better.

Shawna Cox Pro Se'

Filed 09/06/16

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