Case 3:16-cr-00051-BR

Document 1470

Filed 10/19/16

Page 1 of 3

Jesse Merrithew, OSB No. 074564

Email: jesse@lmhlegal.com
Levi Merrithew Horst PC
610 SW Alder Street, Suite 415
Portland, Oregon 97205
Telephone: (971) 229-1241
Facsimile: (971) 544-7092

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

UNITED STATES OF AMERICA,

Case No.: 3:16-CR-00051-BR-26

Plaintiff,
vs.

DECLARATION OF JESSE
MERRITHEW

JAKE RYAN, et al.,

Defendants.
I, Jesse Merrithew, hereby depose and state that to the best of my knowledge and belief
the following is true and correct:
1. I represent Jake Ryan in the above-entitled case. I was appointed to represent him on
April 6, 2016 (nunc pro tunc to March 18, 2016), directly following his arrest.
2. Mr. Ryan was released with conditions after a hearing on June 2, 2016. Among the
conditions the Court required was a curfew, to be monitored by a radio frequency ankle
bracelet.
3. In the over four months since Mr. Ryans release, he has not had any issues with
complying with his release conditions. He has gained the trust of his supervising officer

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Case 3:16-cr-00051-BR

Document 1470

Filed 10/19/16

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to the extent where he is regularly allowed to attend various events outside of his regular
curfew time. Mr. Ryan expresses respect for his supervising officer and believes they
have a good relationship.
4. Pursuant to another condition of his pre-trial release, Mr. Ryan is employed full time. He
works in a rock quarry selecting rocks with the assistance of heavy equipment for
landscaping wholesalers. This work regularly requires him to climb among large loose
rocks. The ankle bracelet is a hazard in this situation as it sticks out from his ankle and
gets hung up on rocks.
5. Mr. Ryan is required to bear the costs of the monitoring equipment which comes in the
form of a monthly fee. While the cost (<$100) may seem insignificant, it is expensive
given Mr. Ryans financial circumstances.
6. On two occasions, Mr. Ryan was apparently wrongly identified as attempting to leave the
jurisdiction once into Canada and once into Puerto Rico. On both occasions, he was at
home with his ankle bracelet on. USPT called his home phone and spoke with him to
confirm his presence there. Given this situation, it would seem that this type of phone call
would be a more accurate and far less expensive means to insure compliance with release
conditions.
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Page 2 DECLARATION OF JESSE MERRITHEW

LEVI MERRITHEW HORST PC

610 SW Alder Street, Ste 415
Portland, Oregon 97205

Case 3:16-cr-00051-BR

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Filed 10/19/16

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7. Mr. Ryan is the last named defendant on the indictment. His exposure, if convicted, is
relatively minimal. He has voluntarily travelled to Portland on multiple occasions with
the permission of USPT to attend court hearings and portions of the September trial. Like
many if not all of the other defendants in this case, he wants his day in court.

DATED this 19th day of October, 2016

By:
/s Jesse Merrithew
Jesse Merrithew, OSB No. 074564
Attorney for Jake Ryan

Page 3 DECLARATION OF JESSE MERRITHEW

LEVI MERRITHEW HORST PC

610 SW Alder Street, Ste 415
Portland, Oregon 97205