Case 3:16-cr-00051-BR

Document 1036

Filed 08/15/16

Page 1 of 3

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
UNITED STATES OF AMERICA
v.

3:16-CR-00051-BR-19
GOVERNMENTS MOTION TO
CONTINUE SENTENCING

COREY LEQUIEU,
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, hereby moves this Court for an order continuing the
sentencing hearing for defendant Lequieu from August 16, 2016, to a date in early December
2016.
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Case 3:16-cr-00051-BR

I.

Document 1036

Filed 08/15/16

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Certificate of Conferral
Defendant, through his attorney, Ramon Pagan, opposes this motion.

II.

A Continuance Is Requested for the Victims and for Restitution Matters

The bases of this motion are as follows: (1) victims of the Conspiracy to Impede Federal

Officers are unable to attend the hearing on August 16, 2016; and (2) a separate restitution
hearing will be needed in the future with a new attorney for defendant Lequieu.
Due to Mr. Pagans need to withdraw as counsel for defendant Lequieu, the government
respectfully recommends that the hearing on August 16 remain on the calendar, but instead be
converted to a hearing to substitute defense counsel.
The government will be filing motions to set over the sentencing hearings for all
defendants who have pleaded guilty to a time in early December 2016, so that victims of the
Conspiracy from the Burns, Oregon, area may make a consolidated trip to Portland to present
Victim Impact Statements at the sentencing hearings.
A consolidated restitution hearing will also be necessary in this case.

The government

believes it would be most appropriate for a single defense lawyer to represent defendant Lequieu
for all aspects of his sentencing, including a future restitution hearing.
Defendant Lequieu has been in custody for approximately 6 months.

Pursuant to the

plea agreement, the parties will jointly recommend a sentence of 30 months in prison, so a
continuance of the sentencing date will not result in an extension of Lequieus overall time in
custody.
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Governments Motion to Continue Sentencing

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Case 3:16-cr-00051-BR

III.

Document 1036

Filed 08/15/16

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Sentencing Recommendation
If the Court denies this motion for a continuance and moves forward with sentencing on

August 16, the government recommends 30 months in custody, with 3 years of supervised
release, for the reasons set forth in the Presentence Investigation Report.
Dated this 15th 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

Governments Motion to Continue Sentencing

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