Dangerous Offender and Equal Privileges
The state has just given you and your client notice that they intend to seek a Dangerous Offender sentence. First question you might ask in response, what criteria did the DA's office use to make that determination and does the office apply that criteria consistently? If not, the state has an equal privileges problem.
For a great memo on equal privileges generally, go here. It's written for theft cases, but easily written for dangerous offender if you need to. If you've got this situation in Multnomah County, contact me directly at email@example.com.