BILLY J. WILLIAMS, OSB #901366 

United States Attorney 

District of Oregon 

ETHAN D. KNIGHT, OSB #992984 

GEOFFREY A. BARROW 

CRAIG J. GABRIEL, OSB #012571 

PAMALA R. HOLSINGER, OSB #892638 

Assistant United States Attorneys 

ethan.knight@usdoj.gov 

geoffrey.barrow@usdoj.gov 

craig. gabriel@usdoj.gov 

pamala.holsinger@usdoj.gov 

1000 SW Third Ave., Suite 600 

Portland, OR 97204-2902 

Telephone: (503) 727-1000 

Attorneys for United States of America 

UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

UNITED STATES OF AMERICA 

v. 

AMMON BUNDY, et al., 

Defendants. 

STATE OF OREGON ) 

) ss. 

County of Multnomah ) 

3:16-CR-00051-BR 

AFFIDAVIT OF FBI SPECIAL AGENT 

RONNIE WALKER IN SUPPORT OF 

GOVERNMENT'S SUPPLEMENT AL 

MEMORANDUM 

1. I, Ronnie Walker, being first duly sworn, hereby depose and state as follows: 

I. INTRODUCTION AND AGENT BACKGROUND 

2. I make this affidavit in support of the government's supplemental memorandum in 

support of its motion to enforce the Protective Order. 

Case 3:16-cr-00051-BR Document 1690 Filed 01/10/17 Page 1 of 5
3. I am a Special Agent with the Federal Bureau of Investigation and have been since 

1996. My training and experience includes agency specific training in all aspects of conducting 

federal criminal investigations. I am an "investigative or law enforcement officer of the United 

States" within the meaning of Title 18, United States Code, Section 2510(7), authorized to conduct 

investigations into alleged violations of.federal law. Over the course of my career, I have led or 

participated in numerous federal criminal investigations. I am currently assigned to the Portland 

Division of the FBI and have been assigned to assist with the investigation surrounding the 

January 2016 occupation of the Malheur National Wildlife Refuge (MNWR), a federal wildlife 

refuge operated by the United States Fish and Wildlife located south of Bums, Oregon. 

4. This affidavit is intended to show only facts pertinent for the requested motion and 

does not set forth all of my knowledge about this matter. 

II. RELEVANT FACTS 

5. On January 2, 2016, and continuing through February 11, 2016, several individuals 

to include Dylan ANDERSON, Sandra ANDERSON, Sean ANDERSON, Jeff Wayne BANTA, 

Jason BLOMGREN, Ammon BUNDY, Ryan BUNDY, Brian CAVALIER, Blaine COOPER, 

Shawna COX, Travis COX, Duane Leo EHMER, Eric Lee FLORES, David Lee FRY, Wesley 

KJAR, Corey LEQUIEU, Kenneth MEDENBACH, Joseph O'SHAUGHNESSY, Jason 

PATRICK, Ryan PAYNE, Jon RITZHEIMER, Jake RYAN, Pete SANTILLI, Geoffrey 

STANEK, Darryl William THORN, Neil WAMPLER, and others participated in the illegal 

occupation of the MNWR. 

II I 

Affidavit of FBI SA Ronnie Walker in Support of Government's Supplemental 

Memorandum 

Page 2 

Case 3:16-cr-00051-BR Document 1690 Filed 01/10/17 Page 2 of 5
6. As a result of the occupation, all of the above-named individuals were charged with 

conspiracy to impede by force, intimidation, or threat, officers of the United States from 

discharging their duties in violation of Title 18, United States Code, Section 372. Some of the 

above-named individuals were also charged with possessing a firearm and dangerous weapon in a 

federal facility in violation of Title 18, United States Code, Section 930(b ); theft of government 

property in violation of Title 18, United States Code, Section 641; and/or depredation of 

government property in violation of Title 18, United States Code, Section 1361. Charges against 

Pete SANTILLI were subsequently dismissed. United States v. Ammon Bundy, et al., was 

assigned case number 3: 16-CR-00051-BR. 

7. On February 25, 2016, the Honorable Anna J. Brown, United States District Judge, 

District of Oregon, ordered the government to provide discovery to the defendants. The first 

volume of discovery materials was provided to defense counsel on March 4, 2016. Fifty total 

volumes of discovery materials were provided from March 4, 2016, to October 13, 2016. 

8. On March 9, 2016, Judge Brown entered an Interim Protective Order, court record 

288, which stated that defense counsel may provide copies of discovery only to individuals fmiher 

described in the order. 

9. On March 24, 2016, Judge Brown entered the final Protective Order, court record 

342, which stated defense counsel may provide copies of discovery only to: 1) the defendants in 

this case; 2) persons employed by the attorney of record who are necessary to assist counsel of 

record in preparation for trial or other proceedings in this case; and 3) persons who defense counsel 

deems necessary to further legitimate investigations and preparations of this case. 

Affidavit of FBI SA Ronnie Walker in Support of Government's Supplemental 

Memorandum 

Page3 

Case 3:16-cr-00051-BR Document 1690 Filed 01/10/17 Page 3 of 5
10. The Protective Order further ordered that defense counsel shall provide a copy of 

the Protective Order to any person who receives copies of discovery and that any person who 

receives copies of discovery from defense counsel shall use the discovery only to assist the defense 

in the investigation and preparation of this case and shall not reproduce or disseminate the 

discovery material to any other person or entity. The Protective Order applied only to 1) 

statements by witnesses and defendants to government officials, 2) sealed documents, and 3) 

evidence received from searches of electronic media. 

11. Every document provided to defense counsel in discovery was marked in the lower 

left hand column "Dissemination Limited by Court Order." 

12. On September 7, 2016, trial began for seven of the above-named defendants. The 

trial concluded on October 27, 2016, and all seven defendants were acquitted of the charged 

conspiracy. Prior to the first trial, eleven defendants pled guilty. A second trial for the 

remaining seven defendants is scheduled to begin February 14, 2017. 

13. Beginning November 15, 2016, Gary HUNT began publishing excerpts from the 

discovery materials on the Outpost of Freedom blog at http://outpost-of-freedom.com. 

14. On January 5, 2017, HUNT was served a cease and desist letter which directed him 

to stop publishing excerpts from the above-described discovery materials that were in his 

possession and in violation of the Protective Order. 

15. On January 5, 2017, Sarah Redd-Buck posted a message on her Facebook page 

which stated "Gary Hunt just received a visit today from FBI serving him a cease and desist letter 

because he was publishing factual discovery that has been leaked to him that is still under seal." 

Affidavit of FBI SA Ronnie Walker in Support of Government's Supplemental 

Memorandum 

Page4 

Case 3:16-cr-00051-BR Document 1690 Filed 01/10/17 Page 4 of 5
On January 6, 2017, another individual posted a question on that same page asking "Who is Gary 

Hunt?" That same day, the message "He is working with our lawyers" was posted in reply from 

defendant Duane EHMER's Facebook account. Sarah Redd-Buck and Duane EHMER's 

Facebook accounts are not private and can be viewed by anyone accessing Facebook. 

16. A copy of the above-mentioned messages has been attached to this affidavit. 

~ · 

Ronnie Walker 

Special Agent 

Federal Bureau of Investigation 

~ SUBSCRIBED and SWORN to before me this /V day of January 2017. 

OFFICIAL STAMP 

KENNETH M SCANLON 

NOTARY PUBLIC-OREGON 

COMMISSION NO. 921481 

MY COMMISSION EXPIRES OCTOBER 24, 2017 

Notary Public for Oregon 

Affidavit of FBI SA Ronnie Walker in Support of Government's Supplemental 

Memorandum 

Page 5 

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