Court filing — No. 3:22-cr-00184 (Dkt. 16, D. Or.)
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Case 3:22-cr-00184-SI Document 16 Filed 09/09/22 Page 1 of 2
WHITNEY P. BOISE, OSB No. 851570
whitney@boisematthews.com
BRIDGET M. DONEGAN, OSB No. 103753
bridget@boisematthews.com
BOISE MATTHEWS LLP
Fox Tower
805 S.W. Broadway, Suite 1900
Portland, OR 97205
(503) 228-0487
Of Attorneys for Defendant Michael James DeFrees
UNITED STATES DISTRICT COURT
DISTRICT OF OREGON
PORTLAND DIVISION
UNITED STATES OF AMERICA, Case No. 3:22-CR-00184-SI
Plaintiff,
DECLARATION OF BRIDGET M.
v. DONEGAN IN SUPPORT OF
DEFENDANT’S UNOPPOSED
MICHAEL JAMES DEFREES, MOTION FOR CONTINUANCE
OF TRIAL DATE
Defendant.
I, BRIDGET M. DONEGAN, hereby declare and say:
1. I have been retained to represent defendant Michael James DeFrees.
2. Mr. DeFrees is out on pretrial release and in good contact with his attorneys.
3. Mr. DeFrees is charged via indictment with two counts of Wire Fraud, in violation of
18 U.S.C. §1343, one count of Bank Fraud, in violation of 18 U.S.C. §1344, and one count of Money
Laundering, in violation of 18 U.S.C. §1957.
BOISE MATTHEWS LLP
805 SW Broadway, Suite 1900
Page 1 – DECLARATION OF BRIDGET M. DONEGAN IN SUPPORT Portland, OR 97205
OF DEFENDANT’S UNOPPOSED MOTION TO CONTINUE TRIAL Telephone: (503) 228-0487
Facsimile: (503) 227-5984
Case 3:22-cr-00184-SI Document 16 Filed 09/09/22 Page 2 of 2
4. Mr. DeFrees first appeared in this matter on August 11, 2022, and was given a trial
date of September 20, 2022.
5. Counsel has secured Volume 1 of the discovery from the government and has been
able to review it but has not been able to conduct investigation or complete the review of the case
with Mr. DeFrees.
6. Counsel has spoken with Mr. DeFrees and Mr. DeFrees authorized counsel to waive
his statutory and Constitutional speedy trial rights for this Court to grant the motion to continue so
that counsel could complete the necessary work on his behalf.
7. Assistant United States Attorney Ryan Bounds has advised that the government has
no objection to the allowance of this motion.
8. I hereby declare under penalty of perjury that the above statements are true to the best
of my knowledge and belief.
DATED this 9th day of September, 2022.
s/ Bridget M. Donegan
BRIDGET M. DONEGAN, OSB #103753
bridget@boisematthews.com
(503) 228-0487
Of Attorneys for Defendant Michael James DeFrees
BOISE MATTHEWS LLP
805 SW Broadway, Suite 1900
Page 2 – DECLARATION OF BRIDGET M. DONEGAN IN SUPPORT Portland, OR 97205
OF DEFENDANT’S UNOPPOSED MOTION TO CONTINUE TRIAL Telephone: (503) 228-0487
Facsimile: (503) 227-5984