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 

PROPOSED PROTECTIVE 

ORDER

THIS MATTER having come before the Court, with the Court being fully apprised as to 

the proceedings herein, it is HEREBY ORDERED THAT:

1. Designation of Confidential Information

a. Any party to this action shall have the right to designate any information, 

document, or thing as “confidential information.” “Confidential information” 

means information that disclosure of which would, the party contends in good 

faith, would likely cause harm to a witness, danger of witness intimidation, or 

is information vital to national security.

2. Once a party designates information as confidential information and provides to the 

other party, the designating party may file a motion, under seal to the court with 

Case 3:16-cr-00051-BR Document 367 Filed 04/05/16 Page 1 of 3
discovery attached and evidence that demonstrates good cause for that information to 

be subject to a protective order. That motion must be filed within 5 days of 

disclosing that information to the opposing party, along with the motion to seal, to the 

defense, after conferring with counsel. The parties will agree not to disclose that 

information while the motion is pending ruling by the Court.

3. A designation as confidential information and the following of the protective order by 

a party to this litigation shall not be construed as a concession by that party that the 

information, documents, or things are in fact in good faith confidential. If, 

subsequent to the court’s ruling of confidentiality or after a previous agreement after 

conferral that documents may be deemed confidential, a party to this case may move 

the Court for determination that the confidentiality designation shall be removed.

4. Nothing in this protective order shall bar or otherwise restrict any attorney from 

rendering advice to his client with respect to this action, or from generally referring to 

or relying upon his examination or receipt of information subject to a protective 

order. Nothing in this protective order will prevent a party from reading portions of 

discovery to a potential witness.

5. If Plaintiff has given confidential information to a Defendant and the information is 

ruled subject to a protective order after the Court finds that the Government has 

shown good cause for it to be so designated:

i. Physical and electronic access of copies of the discovery shall be limited to the 

parties, counsel for the parties, agents of counsel for the parties, and any experts 

and investigators;

Case 3:16-cr-00051-BR Document 367 Filed 04/05/16 Page 2 of 3
ii. Any expert or investigator utilized by the parties to review confidential 

information must agree to be bound by the terms of this protective order;

iii. A copy of confidential information may be provided to the receiving party as set 

forth above;

iv. Copies of confidential information may be made available by counsel for the 

parties to agents of counsel for the parties, and any experts and investigators, 

provided that they agree to comply with the terms of this Protective Order;

v. Confidential information shall not be made public by the receiving party;

vi. Confidential information may be used to conduct an investigation, to support 

motion practice, at hearings, in settlement negotiations, and at trial, without 

seeking permission from the court. 

vii. The parties to this Protective Order and all individuals to whom confidential 

information has been divulged as a result of this Protective Order shall remain 

bound to the terms of this Protective Order throughout the disposition of this case, 

and thereafter. 

DATED this _____day of April, 2016

By: ________________________ 

 Judge Anna D. Brown

Case 3:16-cr-00051-BR Document 367 Filed 04/05/16 Page 3 of 3