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LISSA CASEY, OSB #086541

MICHAEL ARNOLD, OSB #011873

lissa@arnoldlawfirm.com

mike@arnoldlawfirm.com

Arnold Law

401 East 10th Ave. Ste 400

Eugene, OR 97401

Ph: 541-338-9111

Attorneys for Ammon Bundy

UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON

UNITED STATES OF AMERICA,

Plaintiff,

vs.

AMMON BUNDY et al,

 Defendants.

Case No.: 3:16-CR-00051

DEFENDANT AMMON BUNDY’S 

MOTION FOR LEAVE TO FILE 

MEMORANDUM OVER 10 PAGES IN 

SUPPORT OF MOTION TO DISMISS 

FOR LACK OF JURISDICTION

Comes now AMMON BUNDY, through counsel ARNOLD LAW, and moves the Court 

for leave to file a memorandum in support of his Motion to Dismiss for Lack of Jurisdiction. 

Certificate of Conferral: On Monday, April 25, 2016, counsel conferred with AUSA Knight 

about this request via email. I left him a voicemail to attempt to confer with him in real time, but 

I could not talk with him via phone prior to filing this document. However, he told me via email 

that the Government does not oppose the defense’s request if the request is for permission for 

less than 15 pages. The memorandum is 13 pages, with 149 pages of exhibits attached.

In its order dated April 11, 2016, the Court limited all memoranda in support of motions 

to ten pages or less, “unless after a good-cause showing before the motion...is filed[,] the Court 

grants leave to file a longer memorandum.” (CR-389 at 5-6).

Case 3:16-cr-00051-BR Document 463 Filed 04/26/16 Page 1 of 2
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This motion to dismiss addresses complex legal issues that inform the court on how to 

conduct an inquiry on whether it has jurisdiction in this case. These issues are critically 

important for the protesters to bring before the court, and they require analysis of case law, the 

Constitutional Convention of 1787, land use doctrines, the intersection of the Enclave and 

Property clause, and historical documents, including the Federalist Papers. For example, just last 

month, the Utah House of Representatives endorsed a lawsuit with a reportedly projected cost of 

$14 million dollars, illustrating it is a very complex matter in a case that has already been 

deemed complex over Defendant’s objection. http://www.sltrib.com/news/politics/3631326-

155/utah-house-endorses-14-million-public

These issues implicate wide-reaching and controversial issues in constitutional law, and 

in order to bring all information before the Court for its consideration of this issue, Defendants 

respectfully request more than 10 pages to do so. Defendant maintains that it is a Due Process 

violation to limit counsel in the arguments they can make and ensure a complete record for their 

clients. Counsel has a duty to Mr. Bundy in this case (that has already been declared complex) to 

litigate these complex issues thoroughly, competently, and while protecting his record and his

Constitutional rights. If this case is complex, then Defendant respectfully requests the ability to 

address these complex issues and make a complete record in doing so. 

Respectfully submitted on the 26th day of April, 2016. 

/s/ Michael Arnold

Michael Arnold, OSB #011873

mike@arnoldlawfirm.com

Lissa Casey, OSB #086541

lissa@arnoldlawfirm.com

Case 3:16-cr-00051-BR Document 463 Filed 04/26/16 Page 2 of 2