Case 3:16-cr-00051-BR

Document 1418

Filed 10/12/16

Page 1 of 2

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

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF OREGON
UNITED STATES OF AMERICA,
Plaintiff,
v.
JOSEPH O=SHAUGHNESSY,

No. 3:16-cr-00051-BR-03
DECLARATION OF COUNSEL IN
SUPPORT OF DEFENDANT=S
UNOPPOSED MOTION TO
CONTINUE SENTENCING

Defendant.
I, Amy Baggio, declare that the following statements are true to the best of my
knowledge, information and belief:
1. I represent the defendant, Joseph OShaughnessy, in the above-captioned case.
2. In August 2016, Mr. OShaughnessy pled guilty in the District of Oregon (CR-962)
and was transferred to the District of Nevada for further proceedings in a criminal
case pending in that district (CR-972). He remains incarcerated in the District of
Nevada at this time.
3. The current sentencing date for the District of Oregon case is December 2, 2016.

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CONTINUE SENTENCING

Case 3:16-cr-00051-BR

Document 1418

Filed 10/12/16

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4. Proceedings in the District of Nevada are ongoing. Mr. OShaughnessy has

requested that his Oregon sentencing be continued so that he can continue to focus
his time and attention on the Nevada case.
5. I contacted AUSA Craig Gabriel regarding this motion to continue sentencing;
AUSA Gabriel stated that he has no objection to the request.
6. On behalf of Mr. OShaughnessy, I request the Court reschedule the District of
Oregon sentencing proceeding to a date in April of 2017 in order to allow the
defendant to concentrate on his Nevada case and to allow me time to work with
him subsequent to conclusion of those proceedings so as to prepare the case for
sentencing in this district.
I declare under penalty of perjury under the laws of the United States that the foregoing is true
and correct.
Respectfully submitted on October 12, 2016.
/s/ Amy Baggio
Amy Baggio, OSB #011920
503-222-9830
Attorney for Defendant O=Shaughnessy

Page 2 DECLARATION OF COUNSEL IN SUPPORT OF DEFENDANT=S UNOPPOSED MOTION TO

CONTINUE SENTENCING