Case 3:16-cr-00051-BR

Document 1269

Filed 09/13/16

Page 1 of 4

AT THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF OREGON
PORTLAND DIVISION
UNITED STATES,
Plaintiff,
v.
RYAN BUNDY,
Defendant named in error.

CASE NO. 3:16-cr-00051-BR-05]

AFFIDAVIT
VERIFIED

NOTICE OF MOTION TO PROHIBIT THE INTRODUCTION OF EVIDENCE BY US

ATTORNEYS FOR FAILURE TO FILE AN ADEQUATE BILL OF PARTICULARS
Dear Equire(s):
PLEASE TAKE NOTICE, that upon the annexed affidavit of Billy J Williams, and all
papers and proceedings heretofore had herein, the undersigned will move this Court at
a term of motions thereof, to be held at the Courthouse at Courts of Law 1000 Sw 3rd
Ave, Portland, Oregon. On 9/13/16 at 9 a.m. or as soon thereafter as defendant can be
heard, for an order prohibiting the United States Attorney from introducing upon the trial
of this case evidence tending to establish any of the following: That Ryan Bundy is in
violation of 18 U.S.C. 372, 18 U.S.C. 930(b) and 2, 18 U.S.C. 924(c)(1)(A) and 2,
and 18 U.S.C. 641.
The ground upon which this motion is based is that the bill of particulars filed by the
United States Attorney herein is totally inadequate and nonresponsive, and represents a
deliberate attempt to evade the requirements of the Order of the Hon. Anna Brown
directing that the aforementioned information be given to the Defendants, and for such
other relief as may be just and proper.

Case 3:16-cr-00051-BR

Document 1269

Filed 09/13/16

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Respectfully submitted,
/s/ryan c bundy
______________________________
ryan c of the bundy society
Dated: 9/12/16
Verification
I certify the foregoing is true and correct under the
penalty of perjury pursuant to 28 USC 1746 that I
am over the age of 18 years, that I have personal
knowledge of the facts stated herein, and that I am
fully competent to testify to those facts.
/s/ryan c bundy
_________________________
ryan c of the bundy society

Certificate of Service
This the 12th day of September 2016 a true and correct
copy of the foregoing was served to the court, and
opposing counsel by first-class mail or better.
/s/ryan c bundy
______________________
ryan c of the bundy society

TO: HON. Billy J Williams

Case 3:16-cr-00051-BR

Document 1269

Filed 09/13/16

Page 3 of 4

AT THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF OREGON
PORTLAND DIVISION
UNITED STATES,
Plaintiff,
v.
RYAN BUNDY,
Defendant named in error.

CASE NO. 3:16-cr-00051-BR-05]

AFFIDAVIT
VERIFIED

DEFENDANTS AFFIDAVIT IN SUPPORT OF MOTION TO PROHIBIT

THE INTRODUCTION OF EVIDENCE BY THE UNITED STATES ATTORNEY
FOR FAILURE TO FILE AN ADEQUATE BILL OF PARTICULARS
RYAN BUNDY, being duly sworn, deposes and says:
1. I am the Defendant herein.
2. On March 8th 2016, Defendant was indicted for the crime of conspiracy and
possession of firearms, Use of a fire arm in relation to violence, and theft of property by
District of Oregon Portland Division Grand Jury. (Exhibit A annexed hereto).
3. On May 26th, Hon. Anna Brown, in response to Defendants motion for a bill of
particulars (Exhibit B annexed hereto) ordered (Exhibit C annexed hereto) the United
States Attorney to make available to the Defendant the following information: A factual
basis and summary for each of the crimes the defendant is charged.
4. On June 6th 2016, after an unwarranted delay, a bill of particulars was served on the
Defendant. (Exhibit D annexed hereto.)
5. The bill of particulars which was served is vague, indefinite and ambiguous and
Defendant is still unable to ascertain the nature of the crime with which he is charged.

Case 3:16-cr-00051-BR

Document 1269

Filed 09/13/16

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6. The delay of the United States Attorney, together with the totally inadequate bill of
particulars, will irrevocably injure the Defendant by compelling him to go to trial on
charges of which he has not been fully apprised, thereby resulting in the denial of
effective assistance under the Sixth Amendment and due process of law under the
Fourteenth Amendment to the United States Constitution.
WHEREFORE, I respectfully request that the relief sought in the notice of motion be in
all respects granted.

Respectfully submitted,
/s/ryan c bundy
______________________________
ryan c of the bundy society
Dated: 8/31/16
Verification
I certify the foregoing is true and correct under
the penalty of perjury pursuant to 28 USC
1746 that I am over the age of 18 years, that I
have personal knowledge of the facts stated
herein, and that I am fully competent to testify to
those facts.
/s/ryan c bundy
_________________________
ryan c of the bundy society
Certificate of Service
This the 31st day of August 2016 a true and correct
copy of the foregoing was served to the court, and
opposing counsel by first-class mail or better.
/s/ryan c bundy
______________________
ryan c of the bundy society