Fit.m}3FEB'1612:181.JSOC-oo> 

UNDER SEAL 

UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

PORTLAND DIVISION 

UNITED STATES OF AMERICA 3:16-CR-0 005/-,l} Av. 

AMMON BUNDY, 

JON RITZHEIMER, 

JOSEPH O'SHAUGHNESSY, 

RYAN PAYNE, 

RYAN BUNDY, 

BRIAN CAVALIER, 

SHAWNA COX, 

PETER SANTILLI, 

JASON PATRICK, 

DUANE LEO EHMER, 

DYLAN ANDERSON, 

SEAN ANDERSON, 

DAVID LEE FRY, 

JEFF WAYNE BANTA, 

SANDRA LYNN PFEIFER ANDERSON, and 

KENNETH MEDENBACH, 

Defendants. 

THE GRAND JURY CHARGES: 

COUNT 1 

(Conspiracy to Impede Officers of the United States) 

(18 u.s.c. § 372) 

INDICTMENT 

18 u.s.c. § 372 

UNDER SEAL 

On or about October 5, 2015, and continuing through the date of this indictment, in the 

District of Oregon, defendants AMMON BUNDY, JON RITZHEIMER, JOSEPH 

O'SHAUGHNESSY, RYAN PAYNE, RYAN BUNDY, BRIAN CAVALIER, SHAWNA 

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COX, PETER SANTILLI, JASON PATRICK, DUANE LEO EHMER, DYLAN 

ANDERSON, SEAN ANDERSON, DAVID LEE FRY, JEFF WAYNE BANTA, SANDRA 

LYNN PFEIFER ANDERSON, and KENNETH MEDENBACH, did knowingly and willfully 

conspire and agree together and with each other and with persons known and unknown to the 

Grand Jury to prevent by force, intimidation, and threats, officers and employees of the United 

States Fish and Wildlife Service, an agency within the Department of the Interior, from 

discharging the duties of their office at the Malheur National Wildlife Refuge, in violation of 

Title 18, United States Code, Section 372. 

In furtherance of the conspiracy and to effect the illegal objects thereof, one or more of 

the defendants and one or more of the conspirators performed the following overt acts in the 

District of Oregon and elsewhere, including but not limited to the following: 

a. On or about October 5, 2015, two conspirators traveled to Harney County, 

Oregon, to warn the Hamey County sheriff of "extreme civil unrest" if certain demands 

were not met. 

b. Beginning on January 2, 2016, defendants and conspirators occupied the 

Malheur National Wildlife Refuge by force while using and carrying firearms. 

c. Beginning on January 2, 2016, defendants and conspirators brandished 

and carried firearms on the premises of the Malheur National Wildlife Refuge and 

prevented federal officials from performing their official duties by force, threats and 

intimidation. 

d. Beginning on January 2, 2016, defendants and conspirators refused to 

leave the Malheur National Wildlife Refuge and allow federal officials to return to their 

official duties. 

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e. Beginning on January 2, 2016, defendants and conspirators threatened 

violence against anybody who attempted to remove them from the Malheur National 

Wildlife Refuge. 

f. Beginning in or about November 2015, defendants and conspirators 

recruited and encouraged other individuals, known and unknown to the grand jury, in 

person and through social media and other means of communication, to participate and 

assist in the above-described conspiracy. 

g. In or about November 2015 continuing through January 26, 2016, 

defendants and conspirators traveled to Harney County, Oregon, to intimidate and coerce 

the population of Harney County, Oregon, in order to effectuate the goals of the 

conspiracy. 

Dated this ""S 

Presented by: 

BILLY J. WILLIAMS 

day of February 2016. 

~-ETHAN D. KNIGHT 

GEOFFREY A. BARROW 

Assistant United States Attorneys 

Indictment 

A TRUE BILL. 

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