Case 3:16-cr-00051-BR Document 2254 Filed 08/28/17 Page 1 of 4 Lisa Hay, OSB #980628 Federal Public Defender Jessica Snyder, OSB #134911 Research and Writing Attorney 101 S.W. Main Street, Suite 1700 Portland, Oregon 97204 Tel: (503) 326-2123 Fax: (503) 326-5524 lisa_hay@fd.org Attorney for Defendant IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON UNITED STATES OF AMERICA, Plaintiff, v. Case No. 3:16-cr-00051-BR JOINT MOTION FOR RESTITUTION JON RITZHEIMER, JOSEPH O’SHAUGHNESSY, RYAN PAYNE, BRIAN CAVALIER, JASON PATRICK, BLAINE COOPER, WESLEY KJAR, COREY LEQUIEU, JASON BLOMGREN, DARRYL THORN, GEOFFREY STANEK, TRAVIS COX, and ERIC FLORES, Defendants. The defendants Jason Blomgren, Brian Cavalier, Blaine Cooper, Travis Cox, Eric Flores, Wesley Kjar, Corey Lequieu, Joseph O’Shaughnessy, Jason Patrick, Ryan Payne, Jon Ritzheimer, Geoffrey Stanek, and Darryl Thorn, along with the government, hereby jointly advise the Court that the parties have conferred and reached an agreement with regard to restitution that is set forth below. Page 1 JOINT MOTION FOR RESTITUTION Case 3:16-cr-00051-BR Document 2254 Filed 08/28/17 Page 2 of 4 For those defendants named above who have been sentenced in this matter, the parties request that the Court enter an Amended Judgment to reflect the agreed-upon terms set forth herein. For those defendants named above who have yet to be sentenced, the parties request that the Court include the below described terms in the final Judgments. The defendants named below have consulted with counsel regarding their obligations under the restitution agreement and relevant restitution statutes. Terms of Restitution The parties agree that each defendant named above shall pay restitution in the amounts specified below. In exchange for defendants’ agreements to make such payments, the government agrees to forgo all other restitution claims. The parties understand and agree that the total amount of any monetary judgment that the Court orders defendants to pay will be due and payable immediately, as limited by the statutory and constitutional provisions relevant to indigent defendants. The parties request that the Court waive interest. The parties have conferred and agreed that defendants named below agree to pay the below amounts to discharge their restitution obligations in this case. The defendants are individually liable for the stated amounts below and are not jointly liable for any other defendant’s restitution obligation. The amounts are as follows: Defendant Amount Jason Blomgren $3,000 Blaine Cooper $7,000 Brian Cavalier $7,000 Travis Cox $3,000 Page 2 JOINT MOTION FOR RESTITUTION Case 3:16-cr-00051-BR Document 2254 Filed 08/28/17 Eric Flores $3,000 Wesley Kjar $3,000 Corey Lequieu $7,000 Joseph O’Shaughnessy $7,000 Jon Ritzheimer $10,000 Jason Patrick $10,000 Ryan Payne $10,000 Geoffrey Stanek $3,000 Darryl Thorn $5,000 Page 3 of 4 Disclosure of Financial Information Defendants agree fully to disclose all assets in which defendants have any interest or over which defendants exercise control, directly or indirectly, including those held by a spouse, nominee or third party. Each defendant found guilty at the trial in this matter agrees to truthfully complete the Financial Disclosure Statement provided herein by 14 days from the date of sentencing, sign it under penalty of perjury and provide it to both the United States Attorney’s Office and the United States Probation Office. For those defendants who pled guilty pursuant to a plea agreement in this matter, said defendants were required by the terms of their plea agreements to submit a Financial Disclosure Statement. Each defendant named above agrees to provide updates to his Financial Disclosure Statement, with any material changes in circumstances, as described in 18 U.S.C. § 3664(k), Page 3 JOINT MOTION FOR RESTITUTION Case 3:16-cr-00051-BR Document 2254 Filed 08/28/17 Page 4 of 4 within seven days of the event giving rise to the changed circumstances, until such time as the defendant has paid the agreed amount of restitution. The defendants authorize the U.S. Attorney’s Office to inspect and copy all financial documents and information held by the U.S. Probation Office, for the purposes of enforcing the restitution agreement. Reservation of Rights The government reserves—and does not waive—its right to pursue any civil remedies for any profit or enrichment of a defendant arising out of the defendants participation in the crime of conviction. The defendants reserve—and do not waive—their rights to defend against any such action. To the extent that any defendant maintains a right to appeal his conviction or sentence, this joint motion and stipulation affect only the potential appeal of the stipulated restitution amount addressed herein. This joint motion and stipulation do not constitute waivers of any other rights or remedies, including but not limited to, the right to appeal any aspect of a defendant’s respective sentence or conviction, other than the stipulated restitution amount addressed herein. Dated this 21st day of August 2017. Respectfully submitted, /s/ Jessica G. Snyder for Lisa Hay (8/21/17) Lisa Hay, OSB #980628 Federal Public Defender Page 4 JOINT MOTION FOR RESTITUTION