Case 2:16-cr-00046-GMN-PAL Document 2350 Filed 09/11/17 Page 1 of 20

1 STEVEN W. MYHRE
Acting United States Attorney
2 District of Nevada
Nevada Bar No. 9635
NADIA J. AHMED
3 Assistant United States Attorneys
ERIN M. CREEGAN
4 Special Assistant United States Attorney
501 Las Vegas Blvd. South, Suite 1100
5 Las Vegas, Nevada 89101
(702) 388-6336
6 steven.myhre@usdoj.gov
nadia.ahmed@usdoj.gov
erin.creegan@usdoj.gov
7
Attorneys for the United States
8
UNITED STATES DISTRICT COURT
9
DISTRICT OF NEVADA
10
UNITED STATES OF AMERICA,
11 2:16-CR-00046-GMN-PAL
Plaintiff,
12 GOVERNMENTS NOTICE AND
v. DISCLOSURES UNDER FEDERAL
13 RULE OF CRIMINAL PROCEDURE
CLIVEN D. BUNDY 16(a)(1)(G)
14
RYAN C. BUNDY
AMMON E. BUNDY,
15
RYAN W. PAYNE,
16 PETER T. SANTILLI
ERIC J. PARKER, and
17 O. SCOTT DREXLER,

18 Defendants.

19
CERTIFICATION: The government certifies that the following Notice and
20
Disclosures set forth herein are timely made.
21
The United States, by and through the undersigned, submits the following
22
Notice pursuant Federal Rule of Criminal Procedure 16(a)(1)(G) and informs the
23
defendants that the government may call all or some of the following witnesses at
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 Case 2:16-cr-00046-GMN-PAL Document 2350 Filed 09/11/17 Page 2 of 20

1 trial to testify in substance as indicated herein, employing such specialized training,

2 education, and experience to testify in the form of an opinion, to provide technical

3 analysis and expertise, or to otherwise assist the trier of fact in understanding the

4 evidence presented at trial, all pursuant to Federal Rules of Evidence 702.

5 Special Agent Chad Simkins, Federal Bureau of Investigation
6
Background. Chad Simkins, Special Agent, Federal Bureau of Investigation, will
7
testify that he holds Bachelors and Masters Degrees in Accounting and is currently
8
a licensed CPA. S/A Simkins attended New Agent Training at the FBI Academy in
9
Quantico, Virginia, from September 2006 to January 2007 and has served as a
10
Special Agent until the present.
11
S/A Simkins is an FBI certified Firearms Instructor and Tactical Instructor
12
and has served as a Supervisor with the Firearms Training Unit at the FBI
13
Academy in Quantico, Virginia, instructing new agents in the use and handling of
14
firearms and firearms skills.
15
In 2014, S/A Simkins was assigned to the Gold Butte Investigation (the name
16
assigned to the investigation of the events culminating in the April 12, 2014,
17
assault, at or near Bunkerville, Nevada). In the course of that assignment, S/A
18

19 Simkins was tasked with applying his training and experience to review and

20 examine all video and photographic media obtained in the course of the Gold Butte

21 Investigation from whatever source derived, whether it be Facebook, YouTube, or

22 conventional media/news sources. In connection with his examination, S/A Simkins

23 was tasked with identifying images of objects he determined to be firearms (as that

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 Case 2:16-cr-00046-GMN-PAL Document 2350 Filed 09/11/17 Page 3 of 20

1 term is defined by law) and identifying persons carrying, using, brandishing, or

2 pointing firearms in and around Toquop Wash (hereinafter the Wash) at all

3 relevant times on and during April 12, 2014, and at such other times and locations

4 as are relevant to the Superseding Indictment.

5 Special Agent Simkins was further tasked with physically viewing the
6
Toquop wash and other relevant locations in and around Bunkerville, Nevada, and
7
to become familiar with known landmarks in the Wash and their positions relative
8
to that of Bundy supporters and federal law enforcement officers as revealed by the
9
photographic evidence he reviewed. With this information, Special Agent Simkins
10
obtained and derived various metrics with regard to known landmarks and the
11
positions of the Bundy supporters and federal law enforcement officers, obtaining
12
and deriving various metrics with regard to each. S/A Simkins was then tasked
13
with creating a diagram, plotting the positions of persons carrying, using,
14
brandishing, pointing firearms relative to known the positions of the law
15
enforcement officers and over time, establishing a timeline and summary of
16
movements of persons with firearms.
17
Summary of Anticipated Testimony.
18

19 S/A Simkins will testify that he reviewed hundreds of hours of video and

20 hundreds of photographs obtained from various sources during the course of the

21 investigation. In connection with that review, he used his investigative skills,

22 training, and experience, to match images captured during the events of April 12

23 with known images of the defendants to establish their identity and presence in or

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1 around the Wash at times relevant in the Superseding Indictment. He used his

2 firearms training and skills to identify persons carrying, using, brandishing, or

3 pointing firearms, and will further describe his observations and understanding of

4 how the weapons were deployed as revealed by the images.

5 He will further testify that he compiled a number of reports and summaries
6
that reflect his analysis. Among those reports and summaries, is a diagram plotting
7
the location and position of persons with firearms (whether carrying, brandishing,
8
or pointing) during two intervals of time: 1) approximately 11:57 to 12:13 during
9
which time, as shown by aerial videos, ground videos and photographs taken during
10
this interval; and 2) approximately 12:13 to 12:28 during which time photographic
11
and video evidence reveals that Supervisory Special Agent Daniel Love was present
12
at the gate speaking with Ammon Bundy.
13
He will further testify that during these two intervals of time, he tallied the
14
number of firearms and types, delineated as handguns and long guns, present in
15
the Wash and on the bridges. He compiled the results of his tally and entered them
16
into a spreadsheet.
17
Special Agent Michael Abercrombie
18

19 Special Agent Abercrombie has served as a Special Agent with the FBI

20 continuously since 2012 and has an extensive military background, having served

21 with the United States Army as an Artillery Officer, Adjutant General Officer, and

22 Civil Affairs Officer (Active, National Guard, and Reserves) since 2003. In connection

23 with his military career, Special Agent Abercrombie has extensive training and

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1 experience in military tactics and marksmanship, including experience in combat

2 during deployments to Iraq and Afghanistan where he planned and executed multiple

3 company and platoon level operations ranging from basic movement to contact to

4 highly complex cordon and search operations involving hundreds of soldiers. Special
5 Agent Abercrombie possesses specialized training and experience in marksmanship,
6
having served as a primary instructor for basic rifle marksmanship with the AK-47,
7
M-4 and M-16, teaching basic shooting positions and proper firing techniques.
8
The government expects that Agent Abercrombie will testify that he has
9
reviewed evidence of still and video images captured during the events occurring in
10
and around Bunkerville, Nevada, on April 12, 2014, including video and images of
11
individuals pointing firearms/rifles from a prone position on the Northbound Bridge
12
of Interstate 15, at the Toquop Wash. Using his specialized training and experience,
13

14 Special Agent Abercrombie will describe, explain and distinguish the characteristics

15 of the positions taken by those individuals in marksmanship terms and opine that

16 the individuals are in a shooting position and the significance of these positions for

17 deploying the rifle. He will further demonstrate the shooting positions taken by these

18 individuals relative to the position of law enforcement officers in the Wash, recreating

19 the scene and calculating the potential range of fire and sight picture each of the

20 individuals would have had on April 12, 2014, based the characteristics of the rife

21 and the position of the marksman.

22

23

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1 Special Agent Joel P. Willis, Federal Bureau of Investigation

2 Special Agent Mark Seyler, Federal Bureau of Investigation

3 Special Agent (S/A) Joel Willis will testify that has been employed as a

4 Special Agent of the FBI for approximately 13 years. He is a graduate of the

5 FBI New Agent Training at Quantico, Virginia, and has participated in hundreds
6
of investigations into allegations of violations of federal law.
7
S/A Mark Seyler will testify that has been employed as a Special Agent with
8
the Federal Bureau of Investigation (FBI), since October 15, 1995, and has
9
participated or led numerous investigations into allegations of violations of federal
10
criminal law.
11
During their careers, Agents Willis and Seyler have received training in the
12
use of computers, the Internet, and social media (Youtube and FaceBook), and have
13
used their training to collect, obtain and analyze evidence of criminal violations
14
from these media. Both agents have extensive experience in obtaining and
15
executing federal search warrants on Facebook, Yahoo!, Microsoft (which maintains
16
the e-mail service Hotmail), and Google, Inc. (which maintains the email service
17
Gmail). Over the course of their careers, both agents have gained considerable
18

19 experience and expertise in reviewing and analyzing social media communications

20 and broadcasts and both have testified in Federal Court on multiple occasions

21 regarding their review and analysis of internet-based information and evidence.

22 In the course of their investigations, S/As Willis and Seyler were tasked with

23 applying their training and experience to obtain process for information from

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1 various intent-based social media outlets, to include Facebook and YouTube,

2 relative to the defendants charged in the Superseding Indictment. Both of these

3 agents examined information obtained from these sources and analyzed various

4 communications and postings revealed by their examination.

5 Summary of Anticipated Testimony
6
Special Agents Willis and Seyler will offer testimony that will assist the jury
7
to understand the Facebook posts and other social media activities of the defendants
8
(including the use of Youtube) as they relate to offenses charged.
9
a. Facebook. Special Agents Willis and Seyler will testify that Facebook
10
allows its users to establish accounts electronically which they then use to share
11
written news, photographs, videos, and other information with other Facebook
12
users, and sometimes with the general public.
13
Facebook asks users to provide basic contact and personal identifying
14
information to Facebook, either during the registration process or thereafter. This
15
information may include the users full name, birth date, gender, contact e-mail
16
addresses, Facebook passwords, Facebook security questions and answers (for
17
password retrieval), physical address (including city, state, and zip code), telephone
18

19 numbers, screen names, websites, and other personal identifiers. Facebook also

20 assigns a user identification number to each account.

21 Facebook users may join one or more groups or networks to connect and

22 interact with other users who are members of the same group or network. Facebook

23 assigns a group identification number to each group. A Facebook user also can

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1 connect directly with individual Facebook users by sending each user a Friend

2 Request. If the recipient of a Friend Request accepts the request, then the two

3 users will become Friends for purposes of Facebook and can exchange

4 communications electronically or view information about each other electronically.

5 Each Facebook users account includes a list of that users Friends and a News
6
Feed, which highlights information about the users Friends, such as profile
7
changes, upcoming events, and birthdays.
8
Facebook users can select different levels of privacy for the communications
9
and information associated with their Facebook accounts. By adjusting these
10
privacy settings, a Facebook user can make information available only to himself or
11
herself, to particular Facebook users, or to anyone with access to the Internet,
12
including people who are not Facebook users. A Facebook user also can create lists
13
of Facebook friends to facilitate the application of these privacy settings. Facebook
14
accounts also include other account settings that users can adjust to controlfor
15
example, the types of notifications they receive from Facebook.
16
Facebook users can create profiles that include photographs, lists of personal
17
interests, and other information. Facebook users also can post status updates
18

19 about their whereabouts and actions, as well as links to videos, photographs,

20 articles, and other items available elsewhere on the Internet. Facebook users also

21 can post information about upcoming events, such as social occasions, by listing

22 the events time, location, host, and guest list. In addition, Facebook users can

23 check in to particular locations or add their geographic locations to their Facebook

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1 posts, thereby revealing their geographic locations at particular dates and times. A

2 particular users profile page also includes a Timeline, which is a space where the

3 user and his or her Friends can post messages, attachments, and links that will

4 typically be visible to anyone who can view the users profile.

5 Facebook allows users to upload photos and videos. It also provides users the
6
ability to tag (i.e., label) other Facebook users in a photo or video. When a user is
7
tagged in a photo or video, he or she receives a notification of the tag and a link to
8
see the photo or video. For Facebooks purposes, the photos and videos associated
9
with a users account will include all photos and videos uploaded by that user that
10
have not been deleted, as well as all photos and videos uploaded by any user that
11
have that user tagged in them.
12
Facebook users can exchange private messages on Facebook with other users.
13
These messages, which are similar to e-mail messages, are sent to the recipients
14
Inbox on Facebook, which also stores copies of messages sent by the recipient, as
15
well as other information. Facebook users also can post comments on the Facebook
16
profiles of other users or on their own profiles; such comments are typically
17
associated with a specific posting or item on the profile. In addition, Facebook has
18

19 a Chat feature that allows users to send and receive instant messages through

20 Facebook. These chat communications are stored in the chat history for the account.

21 Facebook also has a Video Calling feature, and although Facebook does not record

22 the calls themselves, it does keep records of the date of each call.

23 If a Facebook user does not want to interact with another user on Facebook,

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1 the first user can block the second user from seeing his or her account.

2 Facebook has a like feature that allows users to give positive feedback or

3 connect to particular pages. Facebook users can like Facebook posts or updates,

4 as well as webpages or content on third-party (i.e., non-Facebook) websites.

5 Facebook users also can become fans of particular Facebook pages.
6
Facebook has a search function that enables its users to search Facebook for
7
keywords, usernames, or pages, among other things. Each Facebook account has
8
an activity log, which is a list of the users posts and other Facebook activities from
9
the inception of the account to the present. The activity log includes stories and
10
photos that the user has been tagged in, as well as connections made through the
11
account, such as liking a Facebook page or adding someone as a friend. The
12
activity log is visible to the user but cannot be viewed by people who visit the users
13
Facebook page.
14
Facebook Notes is a blogging feature available to Facebook users, and it
15
enables users to write and post notes or personal web logs (blogs), or to import
16
their blogs from other services, such as Xanga, Live Journal, and Blogger.
17
In addition to the applications described above, Facebook also provides its
18

19 users with access to thousands of other applications on the Facebook platform.

20 When a Facebook user accesses or uses one of these applications, an update about

21 the users access or use of that application may appear on the users profile page.

22 Some Facebook pages are affiliated with groups of users, rather than one

23 individual user. Membership in the group is monitored and regulated by the

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1 administrator or head of the group, who can invite new members and reject or

2 accept requests by users to enter. Facebook can identify all users who are currently

3 registered to a particular group and can identify the administrator and/or creator

4 of the group. Facebook uses the term Group Contact Info to describe the contact
5 information for the groups creator and/or administrator, as well as a PDF of the
6
current status of the group profile page.
7
Facebook uses the term Neoprint to describe an expanded view of a given
8
user profile. The Neoprint for a given user can include the following information
9
from the users profile: profile contact information; News Feed information; status
10
updates; links to videos, photographs, articles, and other items; Notes; Timeline
11
postings; friend lists, including the friends Facebook user identification numbers;
12
groups and networks of which the user is a member, including the groups Facebook
13
group identification numbers; future and past event postings; rejected Friend
14
requests; comments; gifts; pokes; tags; and information about the users access and
15
use of Facebook applications.
16
Facebook also retains IP logs for a given user ID or IP address. These logs
17
may contain information about the actions taken by the user ID or IP address on
18

19 Facebook, including information about the type of action, the date and time of the

20 action, and the user ID and IP address associated with the action. For example, if

21 a user views a Facebook profile, that users IP log would reflect the fact that the

22 user viewed the profile, and would show when and from what IP address the user

23 did so.

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1 Facebook places small files, known as cookies or machine cookies, on

2 users browsers or devices. Each time a Facebook user accesses Facebook, these

3 cookies are sent from the users browser or device to Facebook. Facebook retains

4 data regarding these cookies which, among other things, can be used by Facebook
5 to determine which Facebook accounts were accessed from a particular browser or
6
device.
7
Social-networking providers like Facebook typically retain additional
8
information about their users accounts, such as information about the length of
9
service (including start date), the types of service utilized, and the means and source
10
of any payments associated with the service (including any credit card or bank
11
account number). In some cases, Facebook users may communicate directly with
12
Facebook about issues relating to their accounts, such as technical problems, billing
13
inquiries, or complaints from other users. Social networking providers like
14
Facebook typically retain records about such communications, including records of
15
contacts between the user and the providers support services, as well as records of
16
any actions taken by the provider or user as a result of the communications.
17
b. YouTube. YouTube is an Internet forum that allows users to share,
18

19 search for, view and comment on video content. Users can access YouTube through

20 the YouTube website or by using a special software application (app) that allows

21 users to access the service through a mobile device.

22 Anyone can watch videos on YouTube. However, a Google Account is necessary

23 to take advantage of Youtubes customizable features. For example, a Google Account

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1 enables users to like videos, save their favorite videos, subscribe to video channels,

2 save videos to watch later, maintain a history of videos theyve watched, and flag

3 videos. YouTube can also personalize video recommendations based on a users video

4 preferences and subscriptions. All of this information is maintained by YouTube in

5 a users private profile.
6
A Google Account is a single account that permits access to all of Googles
7
services, including YouTube. Subscribers obtain a Google Account by registering
8
with Google. During the registration process, Google asks subscribers to provide
9
basic personal information. Such information can include the subscribers full
10
name, physical address, telephone and other identifiers, alternative or recovery
11
email addresses, and, for paying subscribers, means and source of payment
12
(including any credit or bank account number). Such information may constitute
13
evidence of the crimes under investigation because the information can be used to
14
identify the accounts user or users.
15
In order to upload a video, Google requires users to create a YouTube
16
channel. In other words, without a channel, users have no public presence on
17
YouTube. Although Google Accounts dont come with a YouTube channel by default,
18

19 users with a Google Account can choose to create one. To do so, Google only requires

20 the user to input the name of the channel, identify a channel category, and agree to

21 the Terms of Use. When a user uploads a video, Google asks for a variety of

22 information, including a category, title, description, tag (for keyword searches),

23 and location. Therefore, for every video that is posted on YouTube, Google

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1 maintains account information and associated records about the user that posted

2 the video, in addition to the video itself.

3 A video uploaded to YouTube is public by default. This means that anyone

4 can view the video by visiting YouTube. However, a user can also change the
5 privacy settings to permit only certain users to view a video. A user can do this by
6
linking their YouTube account with Google+, a social networking service provided
7
by Google. The user can then select the email addresses or profiles of other Google+
8
users with which the video will be shared. A user can also make a video unlisted,
9
which means that only those with a link to the video can view it. Unlisted videos
10
arent visible to others who visit the channel page and generally do not show up in
11
Youtubes search results.
12
Videos and video channels on YouTube are assigned a uniform resource
13
locator (URL) that directs viewers to specific video content or a particular
14
channel. The URL for a video generally consists of www.youtube.com/watch
15
followed by a series of random alphanumeric characters. The standard URL for a
16
channel generally consists of www.youtube.com/channel/ followed by the unique
17
channel ID, or www.youtube.com/user/ followed by the users custom channel
18

19 name.

20 Google collects a variety of data on YouTube videos. This includes

21 information for each time a video was watched; the comments and shares of a video;

22 the demographics of viewers; and the sources of traffic to the videos (i.e., the source

23 webpages and links that a viewer used to land on the video). Additionally, each

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1 time a video is watched, Google states that its servers automatically record logs that

2 can include the page visited, the users IP address, the date and time of the visit,

3 cookies that uniquely identify the users browser or Google account, location data,

4 and other information.

5 Further, Google typically retains certain transactional information about the
6
creation and use of each account on their systems. This information can include the
7
date on which the account was created, the length of service, records of log-in (i.e.,
8
session) times and durations, the types of service utilized, the status of the account
9
(including whether the account is inactive or closed), the methods used to connect
10
to the account (such as logging into the account via Googles website), and other log
11
files that reflect usage of the account. In addition, Google often has records of the
12
Internet Protocol address (IP address) used to register the account and the IP
13
addresses associated with particular logins to the account. Because every device
14
that connects to the Internet must use an IP address, IP address information can
15
help to identify which computers or other devices were used to access the account.
16
In addition, Google collects device-specific information (such as a users
17
hardware model, operating system version, unique device identifiers, and mobile
18

19 network information including phone number), which it may associate with a users

20 Google Account. Further, information maintained by the provider can show how

21 and when the account was accessed or used. For example, providers typically log

22 the Internet Protocol (IP) addresses from which users access the account along with

23 the time and date. By determining the physical location associated with the logged

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1 IP addresses, investigators can understand the chronological and geographic

2 context of the account access and use relating to the crime under investigation.

3 Additionally, information stored at the users account may further indicate the

4 geographic location of the account user at a particular time (e.g., location

5 information integrated into an image or video).
6
Mary Jo Rugwell or other Designated Witness
7
Ms. Rugwell is formerly the District Manager for Southern Nevada District
8
Office (SNDO) in Las Vegas, from 2008 to 2012. It is anticipated that Ms. Rugwell
9
will testify as a summary witness familiar with the business records of the SNDO
10
and will testify as what lands are designated public lands in Southern Nevada,
11
including the Gold Butte area. Ms. Rugwell will also review and present summary
12
testimony regarding SNDOs official interaction and correspondence with Cliven
13
Bundy over the years leading up to the 2012 litigation. The government anticipates
14
that she will provide technical and specialized testimony to explain to the jury the
15
role of BLM in public lands management and technical terms such as impoundment
16
and closure. A summary of her expected testimony has been disclosed in discovery
17
at GB.017148 to GB.017204.
18

19 Erich Smith

20 Mr. Smith is a physical scientist forensic examiner with the FBI Laboratory

21 in Quantico, Virginia, with a discipline in firearms and toolmark identification. His

22 CV is located at Exhibit 4, ECF No. 1250. Mr. Smith will testify that he reviewed

23 photographic/video evidence/images adduced during the Gold Butte investigation.

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1 It is anticipated that Mr. Smith will apply his training and experience and render

2 an opinion on whether the objects depicted in the images correspond with a known

3 make/model/type of firearm and whether that make/model/type of firearm is

4 designed to expel a projectile by the action of an explosive (18 U.S.C. 921 (a)(3)).
5 Where available, Mr. Smith will physically examine any firearms introduced into
6
evidence at trial and, where applicable, explain the characteristics of the firearm
7
and the mechanism of fire. Mr. Smiths expected testimony is contained in his
8
report produced as GB.021970-GB.022116.
9
Charles J. Key
10
Charles J. Key will testify as an expert in the use of force by law enforcement
11
officers. Mr. Key was a member of the Baltimore Police Department for over
12
twenty-five years and a supervisor in that agency for over twenty-one years. He
13
retired as the Commanding Officer of the Firearms Training Unit, a position he
14
held for ten years. He has evaluated use of force events for over thirty years. As a
15
supervisor with the Baltimore Police Department, he sat as a member of various
16
tribunals in numerous Administrative Hearings; investigated dozens of uses of less
17
than lethal force; assisted Internal Investigation Division in
18

19 evaluating/investigating hundreds of police involved shootings; and wrote the

20 Departmental General Order governing the use of force.

21 Currently, Mr. Key is an independent contractor and expert witness in police

22 misconduct litigation. In this capacity, he has reviewed numerous cases involving

23 alleged police misconduct, for both plaintiffs and defendants. In such cases, he

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1 evaluated various factor in order to determine if the conduct of the law enforcement

2 personnel and/or agencies violated legal, ethical, and/or constitutional standards of

3 conduct. Those factors include, but are not limited to: the conduct of individual

4 law enforcement officers, the adequacy of the training and supervision received by
5 such officers, and the adequacy and appropriateness of police department policies
6
and procedures.
7
The government anticipates that Mr. Key will provide expert testimony in
8
the areas of: 1) Police/Agent Use of Force; 2) Police/Agent Training; 3) Police/Agency
9
Policies and Procedures; and 4) Defensive Skills. Mr. Key has been previously
10
qualified as an expert witness as to police officer use of force in ninety-two courts
11
(75 states; 17 federal).
12
The government anticipates that Mr. Key will testify that he has reviewed
13
sounds and images captured on various recording devices, depicting law
14
enforcement encounters with civilians during impoundment operations conducted
15
by the Bureau of Land Management on April 6, 9, and 12. The government
16
anticipates that he will testify that, based on his training and experience and by
17
employing standard methods for evaluating use of force events, the uses of force by
18

19 U.S. Government Agents/Officers on the relevant dates were objectively reasonable

20 and consistent with accepted standards of police policies, practices, and training. It

21 is anticipated that he will explain his conclusions based on specific police practices

22 and policies that govern the actions of the U.S. Government Agents/Officers during

23 these events and the training they received regarding such encounters, including

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1 but not limited to:

2 a. The threat presented by an individual aggressively advancing on an

3 officer(s) and/or ignoring the lawful commands of an officer;

4 b. Reaction time related to such threats;

5 c. Police training in the circumstances of this incident, including the
6
use of physical control techniques and a TASER.
7
The government anticipates that it may request that Mr. Key be allowed to
8
attend trial at various times to assist counsel and to listen to testimony. If, during
9
the trial, evidence that is specific to police use of force, police training, police
10
policies, and police procedures is offered, Mr. Key is also expected to address those
11
issues in his testimony.
12
DATED this 11th day of September, 2017.
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Respectfully,
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STEVEN W. MYHRE
15 Acting United States Attorney
16 //s//
______________________________
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NADIA J. AHMED
Assistant United States Attorneys
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ERIN M. CREEGAN
19 Special Assistant United States Attorney

20 Attorneys for the United States

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 Case 2:16-cr-00046-GMN-PAL Document 2350 Filed 09/11/17 Page 20 of 20

1 CERTIFICATE OF SERVICE

2 I certify that I am an employee of the United States Attorneys Office. A copy

3 of the foregoing GOVERNMENTS NOTICE AND DISCLOSURES UNDER

4 FEDERAL RULE OF CRIMINAL PROCEDURE 16(a)(1)(G) was served upon

5 counsel of record, via Electronic Case Filing (ECF).
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DATED this 11h day of September, 2017.
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/s/ Steven W. Myhre
9 ______________________________
STEVEN W. MYHRE
10 Acting United States Attorney

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