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David B. Markowitz, OSB No. 742046

DavidMarkowitz@MarkowitzHerbold.com 

Harry B. Wilson, OSB No. 077214 

HarryWilson@MarkowitzHerbold.com 

Laura Salerno Owens, OSB No. 076230 

LauraSalerno@MarkowitzHerbold.com 

MARKOWITZ HERBOLD PC 

3000 Pacwest Center 

1211 SW Fifth Avenue 

Portland, OR 97204-3730 

Telephone: (503) 295-3085 

Fax: (503) 323-9105 

 Attorneys for Collective Interests of Jurors

IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF OREGON 

PORTLAND DIVISION 

UNITED STATES OF AMERICA,

Plaintiff,

vs. 

AMMON BUNDY, et al., 

Defendants.

Case No. 3:16-cr-00051-BR

STIPULATION 

STIPULATION 

On November 28, 2016, Oregonian Publishing Company, LLC, the Associated Press, and 

Oregon Public Broadcasting (the “Interested Media”) filed a Motion to Intervene, to Modify 

Protective Order, and For Release of Jurors’ Names. (Dkt. 1581.) On December 15, 2016, the 

Interested Media filed a supplemental memorandum in support of its original motion. (Dkt. 

1620.) Interested Media are represented by Charles Hinkle and Brad Daniels of Stoel Rives 

LLP. In response to Interested Media’s motion, the Court found that “none of the parties to this 

Case 3:16-cr-00051-BR Document 1732 Filed 01/17/17 Page 1 of 3
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action are in a position to represent the jurors’ collective interests adequately[.]” (Dkt. 1621.) 

Thus, the Court appointed David Markowitz, Laura Salerno Owens, and Harry Wilson of the 

firm Markowitz Herbold PC to represent the “collective interests of such jurors.” (Id.) 

Interested Media and the Collective Interest of the Jurors, through their respective 

counsel, stipulate as follows: 

 Markowitz Herbold will forward Interested Media’s requests for interviews to each of the 

jurors. 

 Each of the jurors can decide for his or herself whether to agree to an interview and 

whether the interview will be anonymous. 

 If a juror agrees to a non-anonymous interview, Markowitz Herbold will facilitate an 

exchange of contact information between Interested Media and the juror. 

 If a juror agrees to an anonymous interview, Markowitz Herbold will arrange for an 

anonymous exchange of questions and answers along terms mutually agreed to between 

the Interested Media and the juror. 

 Markowitz Herbold will not release any of the jurors’ names or contact information 

without their express permission and none of the jurors are obligated to accept the request 

for interviews. 

 The Interested Media will not file any additional motions in this matter seeking to learn 

the names of the jurors without first allowing Markowitz Herbold to again offer the jurors 

the Interested Media’s interview requests along the same terms described herein. 

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Case 3:16-cr-00051-BR Document 1732 Filed 01/17/17 Page 2 of 3
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 As a result of this stipulation, the parties agree the Court may deny the Motion (Dkts. 

1581, 1620) as moot. 

DATED this 17th day of January, 2017. 

IT IS SO STIPULATED: 

___/s/ Charles F. Hinkle_____________ Charles F. Hinkle, OSB No. 710839 

Brad S. Daniels, OSB No. 025178 

Of Attorneys for Oregonian Publishing 

Company, LLC, the Associated Press, and 

Oregon Public Broadcasting 

__/s/ Laura Salerno Owens_______________

David B. Markowitz, OSB No. 742046 

Harry B. Wilson, OSB No. 077214 

Laura Salerno Owens, OSB No. 076230 

Of Attorneys for the Collective Interest of the 

Jurors 

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