BILLY J. WILLIAMS, OSB #901366 

United States Attorney 

District of Oregon 

ETHAN D. KNIGHT, OSB #99298 

GEOFFREY A. BARROW 

CRAIG J. GABRIEL, OSB #01257 

Assistant United States Attorneys 

ethan.knight@usdoj.gov

geoffrey.barrow@usdoj.gov 

craig.gabriel@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.

3:16-CR-00051-BR

MOTION FOR PROTECTIVE ORDER

 The United States of America, by Billy J. Williams, United States Attorney for the 

District of Oregon, and through Ethan D. Knight, Geoffrey A. Barrow, and Craig J. Gabriel, 

Assistant United States Attorneys, hereby moves this Court for a protective order pursuant to 

Rule 16(d)(1) of the Federal Rules of Criminal Procedure, seeking to prevent the dissemination 

of sensitive discovery materials to persons not a party to, or involved in, this case. Good cause 

exists for such an order based on the affidavit of FBI Special Agent Katherine Armstrong, filed 

concurrently herewith. A proposed protective order accompanies this motion. 

Case 3:16-cr-00051-BR Document 245 Filed 03/08/16 Page 1 of 3
Motion for Protective Order Pertaining to Discovery Page 2

 As part of discovery in this case, the government is providing defendants’ attorneys of 

record sensitive discovery material including reports of interviews, law enforcement reports of 

investigative activity, reports of analysis of relevant evidence, and copies of seized physical 

evidence in electronic form. 

 It is requested that this Court order that the discovery material provided in this case may 

be given only to the following individuals: 

(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 investigation and 

preparation of this case. 

 The government also requests that this Court order defense counsel to provide a copy of 

the protective order to any person above who receives copies of the discovery. 

 The government further requests that the protective order allow any person above who 

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

in the investigation and preparation of this case, and shall not allow them to reproduce or 

disseminate the discovery material to any other person or entity. 

 The protective order shall apply only to materials and documents created or written by 

the government, or obtained by the government through warrants or court orders. It shall not 

restrict reproduction or dissemination of discovery materials the government obtained through 

open sources (e.g., social media posts by the defendants or others, news accounts related to the 

events in this case, etc.). 

Case 3:16-cr-00051-BR Document 245 Filed 03/08/16 Page 2 of 3
Motion for Protective Order Pertaining to Discovery Page 3

 If defense counsel believes an exception should be made to the proposed protective order, 

the parties will confer and then seek guidance from this Court. The parties will advise the Court 

by letter of any exceptions made to the protective order. 

 Defendants object to the proposed protective order. 

 Dated this 8th day of March 2016. 

 Respectfully submitted, 

 BILLY J. WILLIAMS 

 United States Attorney 

 s/ Craig J. Gabriel 

 ETHAN D. KNIGHT, OSB #99298 

 GEOFFREY A. BARROW 

 CRAIG J. GABRIEL, OSB #01257 

 Assistant United States Attorneys 

Case 3:16-cr-00051-BR Document 245 Filed 03/08/16 Page 3 of 3