Case 3:16-cr-00051-BR

Document 1332

Filed 09/23/16

Page 1 of 2

ROBERT W. RAINWATER, Oregon State Bar No. 084489

Email: rrainwater@rainwaterlaw.org
Rainwater Law Group
1327 SE Tacoma Street, Suite 239
Portland, Oregon 97202-6639
Telephone: (971) 271-7566
Fax: (503) 231-8276
Attorney for Defendant
JASON CHARLES BLOMGREN

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF OREGON
PORTLAND DIVISION
UNITED STATES OF AMERICA,
Plaintiff
v.
JASON CHARLES BLOMGREN,

No. 3:16-cr-00051-BR
DECLARATION OF COUNSEL IN
SUPPORT OF DEFENDANTS
UNOPPOSED MOTION TO SET
OVER SENTENCING HEARING
DATE

Defendant.
I, Robert W. Rainwater, declare that the following statements are true to the best of my
knowledge, information and belief:
1. The defendant, Jason Blomgren, through his attorney, Robert W. Rainwater, hereby
requests that the court set over the current sentencing date of October 14, 2016 at 3:00 p.m. This
motion is not opposed by Assistant United States Attorney Craig Gabriel. On behalf of Mr. Blomgren
both parties request a date in April 2017.
2. Is necessary to set Mr. Blomgrens sentencing over past the remain co-defendants trial
date in February in order for the Court to have all the information before it to determine an

Page 1 DECLARATION IN SUPPORT OFDEFENDANTS UNOPPOSED MOTION TO SET

OVER SENTENCING HEARING DATE

Case 3:16-cr-00051-BR

Document 1332

Filed 09/23/16

Page 2 of 2

appropriate sentence for Mr. Blomgren.

I declare under penalty of perjury under the laws of the United States that the foregoing is
true and correct.

RESPECTFULLY SUBMITTED this September 23, 2016.

s/ Robert W. Rainwater
Robert W. Rainwater
OSB # 084489
(971) 271-7566
Attorney for Defendant
Jason Charles Blomgren

Page 2 DECLARATION IN SUPPORT OFDEFENDANTS UNOPPOSED MOTION TO SET

OVER SENTENCING HEARING DATE