AO 91(Rev. 11 / 11) Criminal Complaint 

UNITED STATES DISTRICT COURT FILED2?.J~·1609:27USOC-ORP for the 

United States of America 

v. 

Ammon 6UNDY, Jon RITZHEIMER, 

Joseph O'SHAUGHNESSY, Ryan PAYNE, 

Ryan BUNDY, Brian CAVALIER, 

Shawna COX, Peter SANTILLI, 

Defendant(s) 

District of Oregon 

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UNDER SEAL 

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CRIMINAL COMPLAINT 

I, the complainant in this case, state that the following is true to the best of my knowledge and belief. 

On or about the date(s) of January 2, 2016, to the present in the county of Harney in the 

District of ___ eg n ___ , the defendant(s) violated: 

Code Section Offense Description 

18 U.S.C. § 372 Conspiracy to Impede Officers of the United States from discharging their 

official duties through the use of force, intimidation, or threats 

This criminal complaint is based on these facts: 

See attached Affidavit. 

~ Continued on the attached sheet. 

Sworn to before me and signed in my presence. 

Date: 

City and state: Portland, Oregon 

ComplainGni'SSinature 

Katherine Armstrong, Special Agent, FBI 

Printed name and title 

Stacie F. Beckerman, U. S. Magistrate Judge 

Printed name and title 

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UNITED STATES OF AMERICA ) 

) 

DISTRICT OF OREGON ) 

AFFIDAVIT OF KATHERINE ARMSTRONG 

I, Katherine Armstrong, having been first duly sworn, do hereby depose and state as 

follows: 

Introduction and Agent Background 

1. I am a Special Age_nt (SA) of the Federal Bureau oflnvestigation (FBI) and have 

been so employed for approximately one-and-a-half (1 Vi) years. I am currently assigned to the 

FBI's Portland Division and am part of the violent and organized crime squad. In 2014, I 

successfully completed twenty-one (21) weeks of training at the FBI Academy located in 

Quantico, Virginia. During that time, I was taught the use and practical application of various 

investigative techniques that Federal law enforcement officers are allowed to employ. In 

addition to my formalized training in violations of the law at the FBI Academy, I have also 

acquired knowledge and information pertaining to violations of federal law from numerous other 

sources, including: formal and informal training, other law enforcement officers and 

investigators, informants, and my participation in other investigations. Prior to joining the FBI, I 

was a prosecutor with the Philadelphia District Attorney's Office for approximately two-and-ahalf years and briefly worked in the private sector as a civil litigator. I attended law school at 

Temple University in Philadelphia, Pennsylvania, and have been certified to practice law since 

October 2010. 

Purpose of Affidavit 

2. This affidavit is submitted to support a criminal complaint and arrest warrant for 

Ammon BUNDY (hereinafter A. BUNDY), white male, date of birth 09/0111975, Jon 

RITZHEIMER, white male, date of birth 10/31/1983, Joseph O'SHAUGHNESSY, white male, 

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date of birth 03/22/1972, Ryan PAYNE, white male, date of birth 08/05/1983, Ryan BUNDY 

(hereinafter R. BUNDY), white male, date of birth 10/31/1972, Brian CAVALIER, aka "Booda 

Bear," white male, date of birth 05/31/1971, Shawna COX, white female, date of birth 

08/2111956, and Peter SANTILLI, white male, date of birth 04/29/1965, for the felony crime of 

Conspiracy to Impede Officers of the United States from discharging their official duties through 

the use of force, intimidation, or threats, in violation of Title 18, United States Code, Section 

372. The named individuals, most of whom have been armed, have been working together, with 

additional known and unknown actors, to control federal property while refusing to leave, 

intending to impede and prevent by force the federal officials who work on and use that property 

from performing their official duties. 

3. The facts set forth in this affidavit are based on my own personal knowledge; 

knowledge obtained from other individuals during my participation in this investigation, 

including other law enforcement officers; interviews of witnesses; my review of records related 

to this investigation; and communications with others who have knowledge of the events and 

circumstances described herein. 

4. Persons identified by name in the photographs contained herein have been 

independently identified by a witness with knowledge or a law enforcement officer through 

motor vehicle records and/or criminal history records. All photographs of the Malheur National 

Wildlife Refuge that depict the land, entrances/gates, and buildings inside and out have been 

identified by a Federal Wildlife Officer or staff member with the U.S. Fish and Wildlife Service 

who works at the Malheur National Wildlife Refuge. The Federal Wildlife Officer or staff 

member with the U.S Fish and Wildlife Service has confirmed the photographs depict what is 

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represented in this affidavit. All video referenced in this affidavit has been downloaded and 

preserved by investigators. 

5. I have not included all information learned through this investigation. I have 

included information I believe is sufficient to establish probable cause for the criminal complaint 

and arrest warrants requested by this affidavit. 

Investigation 

6. Based on the foregoing facts, I have probable cause to believe that starting on or 

about January 2, 2016, and continuing through the date of this affidavit A. BUNDY, 

RITZHEIMER, O'SHAUGHNESSY, PAYNE, R. BUNDY, CAVALIER, Robert Lavoy 

Finicum, COX, SANTILLI, and other known and unknown individuals did conspire to impede 

by force, intimidation, or threat, officers of the United States from discharging their duties in the 

Malheur National Wildlife Refuge in Harney County, Oregon, in violation of Title 18, United 

States Code, Section 372. 

7. This affidavit is based on an investigation by the FBI into the activities of 

A. BUNDY, RITZHEIMER, O'SHAUGHNESSY, PAYNE, R. BUNDY, CAVALIER, Finicum, 

COX, SANTILLI, and others in connection with an armed occupation of the Malheur National 

Wildlife Refuge (MNWR), a unit of the National Wildlife Refuge System managed by the 

United States Fish and Wildlife Service (USFWS). The MNWR is federal property. 

Hammond Sentencing 

8. On June 6, 2012, Dwight and Steven Hammond were convicted of two counts of 

arson by a jury in the District of Oregon. They were originally sentenced on October 30, 2012. 

Dwight Hammond was sentenced to serve three months in prison, and Steven Hammond was 

sentenced to serve twelve months. On February 7, 2014, the Ninth Circuit Court of Appeals 

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overturned the District Court's sentence. The United States Supreme Court denied a petition for 

writ of certiorari on March 23, 2015. On October 7, 2015, Dwight and Steven Hammond were 

resentenced to serve a mandatory, five-year term of imprisonment. On January 4, 2016, the 

Hammonds reported to a Federal Correctional Institute in California to serve the remainder of 

their sentences. Prior to surrendering to serve their sentences, the Hammonds, through their 

attorney, continued to distance themselves from A. BUNDY and his group. 

9. On January 4, 2016, A. BUNDY addressed the media and stated that he named 

his group of protesters the "Citizens for Constitutional Freedom" (CCF), and they were acting in 

support of the Hammonds. A. BUNDY told a national morning news show that members of 

CCF were armed because "We are serious about being here. We're serious about defending our 

rights, and we are serious about getting some things straightened out." When asked on the show 

ifhe anticipated it would lead to violence, A. BUNDY responded, "Only ifthe government 

wants to take it there. " 

10. In a video posted on an Internet website titled "Citizens for Constitutional 

Freedom News Conference" posted on January 4, 2016, A. BUNDY said their purpose is to 

restore and defend the Constitution, and they have spent two months petitioning the state and 

county representatives to stand for the Hammonds against the so-called "unconstitutional 

actions." Bundy said, "We feel that we have exhausted all prudent measures and have been 

ignored. And it has been left to us to decide whether we allow these things to go on or whether 

we make a stand." In the video, Finicum makes a statement about the purported oppression 

against ranchers, specifically the Hammonds. 

11. On January 4, 2016, Hamey County Sheriff Dave Ward held a press conference 

and informed the armed occupiers of the MNWR that the Hammonds had peacefully surrendered 

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themselves to complete their federal sentences and informed the armed occupiers that "it was 

time to leave." 

Armed Occupier Activity in Harney County, Oregon 

12. On October 5, 2015, A. BUNDY and PAYNE visited Hamey County Sheriff 

Dave Ward in Hamey County. During the visit, A. BUNDY and PAYNE told Ward that he 

needed to protect the Hammonds from going back to prison. PAYNE and A. BUNDY informed 

Ward that if the Hammonds spent one more day in jail there would be "extreme civil unrest." 

On November 12, 2015, A. BUNDY publicly posted a letter from the Bundy family to Hamey 

County Sheriff Dave Ward. The letter was posted online at http://bundyranch.blogspot.com and 

was still publicly viewable as of January 26, 2016. In summary, the Bundy family claims that 

federal employees are abusing their positions within the federal government to punish the 

Hammond family. Several additional blog posts, made on November 12 and later, further state 

that it is the Bundy family position that the Hammond family has been illegally arrested. 

13. A Facebook Community page titled "Hamey County Liberty News" includes 

eight videos on the page. I personally viewed the Facebook page on January 7, 2016, and all 

videos appear to be narrated by the same individual, who identifies himself on several of the 

videos. In one of the videos, posted on December 12, 2015, and titled "Time for some camping" 

the individual is pictured standing outside with the road sign "Hammond Ranch Rd" clearly 

visible in the background. The individual talks about winter camping and camping in the area. 

In a video posted on December 13, 2015, and titled "Through the wind and snow yesterday I 

neglected to post this lovely cattle drive," the individual identifies himself as being present in 

Harney County and later states he is doing some "tactical camping." In an untitled video posted 

December 15, 2015, he discusses a community meeting in Hamey County and shows a flyer for 

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the meeting indicating that it will include a "presentation on Committee of Safety by Ryan 

Payne." 

14. On December 18, 2015, a citizen (hereafter Citizen) of Hamey County was 

shopping at the Safeway grocery store in Bums, Oregon. Citizen was wearing a BLM shirt. 

Citizen was confronted by two men, one whom she identified as RITZHEIMER. Citizen 

reported to law enforcement that she heard yelling, and when she turned around, the second 

individual shouted "you're BLM, you're BLM" at her. That person further stated to Citizen that 

they know what car she drives and would follow her home. He also stated he was going to bum 

Citizen's house down. RITZHEIMER and the second individual left the area in a black pick-up 

truck with black canopy and no visible license plate. Since the incident, Citizen has observed a 

similar vehicle outside her residence. Citizen was unable to identify the driver of the vehicle 

when she later saw it. The following week, a second vehicle, described as a white truck with a 

pink license plate and a big rebel flag sticker on the back window, aggressively tailgated Citizen, 

flashing lights and driving erratically. Citizen believed the second incident was related to the 

first. Citizen also saw the black pick-up truck outside of her place of employment early in the 

morning hours of Christmas Day. 

15. On December 26, 2015, a video posted to an Internet website channel indicated 

the video is a "call out" to all "patriots" to meet at the Safeway parking lot in Bums, Oregon, on 

January 2, 2016, for the protest. One of the individuals states they are in Bums, Oregon, and are 

there to support the Hammonds. A screenshot from the video, attached below, shows 

O'SHAUGHNESSY on the far left and RITZHEIMER on the far right. In the video each 

individual identifies himself by name. Their identities have also been independently confirmed 

through motor vehicle records. 

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16. On December 31, 2015, a video posted to an Internet website showed 

RITZHEIMER in a car saying "we the people need to take a stand," "we need real men and 

women here to take a stand" and that he has "had to do a lot of soul searching" and he is "one 

hundred percent willing to lay down my life, to fight against tyranny in this country." 

January 2016 - Takeover of Malheur National Wildlife Refuge 

17. According to open source reporting that I have reviewed and conversations I have 

had with other law enforcement officers, on January 2, 2016, several hundred unidentified 

individuals participated in a protest in Bums, Oregon, related to the resentencing of Steven and 

Dwight Hammond. Following the protest, A. BUNDY, RITZHEIMER, O'SHAUGHNESSY, 

PAYNE, R. BUNDY, CAVALIER, and Finicum, among others, entered the MNWR, blocked 

the entrance to the Refuge, and began their armed occupation of several buildings within the 

MNWR. The MNWR and all buildings located thereon are federal property and facilities. The 

armed occupation of the MNWR has been continuous and ongoing since Janμary 2, 2016. The 

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MNWR is located in Hamey County, District of Oregon. A news article posted on an Internet 

website on January 3, 2016, at 7:19 a.m. and updated January 4, 2016, at 12:53 p.m. included a 

photo with the caption "The militiamen have blocked the entrance to the headquarters of the 

Malheur National Wildlife Refuge with vehicles" and is shown below. This photograph has 

been verified by a Federal Wildlife Officer with the U.S. Fish and Wildlife Service and 

confirmed to depict the entrance to the MNWR. The Federal Wildlife Officer identified the 

vehicle as an MNWR vehicle blocking the main road. 

18. According to a senior official with the U.S. Fish and Wildlife Service, Pacific 

Region, the MNWR is adjacent to the Steens Mountain Wilderness, with the Wild and Scenic 

Donner and Blitzen River flowing into it at its southern boundary. The MNWR consists of more 

than 187,700 acres of prime habitat, including 120,000 acres of wetlands that provide a crucial 

stop for waterfowl along the Pacific Flyway. Particularly important to colonial waterbirds, 

sandhill cranes, and redband trout, the Refuge also encompasses upland and riparian habitats 

vital to many migrating birds and wildlife. The MNWR hosts over 320 bird species and 58 

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mammal species. The MNWR supports over 20 percent of the Oregon population of breeding 

greater sandhill cranes. Refuge property includes more than 200 miles of water delivery ditches, 

7 major irrigation dams, 450 miles offence, and 200 miles of roads. 

19. Refuge property also contains 13 historic buildings. Many were built by the 

Civilian Conservation Corps in the 1930s and early 1940s. The headquarters features National 

Register of Historic Places structures and landscaping including five wood frame buildings (clad 

with local lava rock and roofed with terra cotta tile) that function as offices, workshops, natural 

resource labs, and visitor facilities. A historic lookout tower, mature landscaping, and modem 

shop, garage, and wetland management infrastructure are also part of the historical headquarters 

ensemble. In 2014, there were 23,967 visitors to the MNWR including birders, hunters and 

outdoor recreationists. The winter hunting season closed at the end of December; currently, 

there are no open hunting seasons on the Refuge. 

20. The MNWR is staffed by employees of the United States Fish and Wildlife 

Service. As a result of the armed occupation of the MNWR by the known conspirators and 

others, which began on or about January 2, 2016, and continuing to the present, employees of the 

USFWS who work at the MNWR have been prevented from reporting to work because of threats 

of violence posed by the defendants and others occupying the property. Sixteen (16) federal 

employees work at the MNWR, including one federal law enforcement officer and a volunteer 

coordinator who lived on the Refuge and works in the visitor center. 

21. According to a senior official with the U.S. Fish and Wildlife Service, Pacific 

Region, following the unauthorized, armed occupation of the MNWR, the staff has been unable 

to conduct any official operations, including but not limited to business elements, critical 

management requirements, law enforcement operations, visitor services, and essential 

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maintenance activities. As a result, the MNWR is being degraded and damaged by the inability 

of the staff to conduct required conservation management operations which are essential to the 

MNWR. The staff is entrusted with the management of the MNWR through the Fish and 

Wildlife Service Mission, the Refuge System Mission, and the governing comprehensive 

conservation planning document which includes the applicable authorities of the Refuge 

Administration Act, the Refuge Improvement Act, as well as supporting acts. In addition, active 

contracts, cooperative agreements, and other partnership arrangements requiring work on the part 

of contractors or collaborative partners are not able to occur as a result of the armed 

occupation. Any and all legal arrangements that exist with contractors and other business 

collaborators are being hindered resulting in loss of time, funding, and critical management 

elements. 

22. USFWS management believes that as long as this unauthorized, armed occupation 

persists, it is unsafe for employees to be in the area. 

23. According to a Special Agent with the Bureau of Land Management (BLM), on 

January 2, 2016, the BLM learned, by watching a live online video stream, that numerous 

individuals to include A. BUNDY and PAYNE left the rally that was in support of the 

Hammonds in Bums, Oregon, and travelled to the MNWR to take it over. BLM was notified 

later that day by a Hamey County Sheriffs Officer that a source informed him that the group 

controlled the MNWR and had explosives, night vision goggles, and weapons and that if they 

didn't get the fight they wanted out there they would bring the fight to town. 

24. Due to the presence of armed individuals occupying the Refuge and also learning 

that some of their associates were still in the Bums area, the BLM made the decision to close the 

Bums District Office, located at 28910 Highway 20 West, Hines, Oregon, 97738. The office is 

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currently closed and has been since January 4, 2016. This BLM action was taken out of concern 

for the safety of the approximate 80 employees who work there. 

Social Media Posts, and News Reports 

25. Since the armed occupation of the MNWR, the occupiers have continually posted 

to various social media accounts and conducted interviews with news media, within and outside 

of the MNWR buildings, as further described below. 

A.BUNDY 

26. On January 3, 2016, a video posted on an Internet website by "The Conspiracy 

Scope" showed A. BUNDY and two others at the MNWR. The location ofthis video at the 

MNWR was confirmed by a Federal Wildlife Officer of the U.S. Fish and Wildlife Service. The 

Federal Wildlife Officer confirmed the individuals are at the main entrance to the MNWR. One 

individual is in the background holding a rifle. A. BUNDY states that we have "taken over the 

Malheur National Wildlife Refuge" and that the MNWR will become a "base place for patriots 

from all over the country to come and be housed." A. BUNDY continues by saying that "we're 

planning on staying here for several years." A. BUNDY also says in the same video, "We are 

calling people to come out here and stand" and "We need you to bring your arms and we need 

you to come to the Malheur National Wildlife Refuge." One individual is also in the video 

saying that he agrees with A. BUNDY and that they need people to "bring your arms." Two 

screen shots were taken from the video. The screen shot on the left shows two individuals (one 

with a rifle), and the screen shot on the right shows an unknown individual armed with a rifle, 

standing with A. BUNDY, shown below: 

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27. On January 4, 2015, A. BUNDY gave a news conference at the MNWR. A photo 

on a news website shows CAVALIER (second from left), A. BUNDY (third from left), and 

others leaving the news conference together, below. According to a Federal Wildlife Officer 

with the U.S. Fish and Wildlife Service who has viewed this photo, the group appears to be 

walking down the hill from the main entrance to the MNWR and toward the main headquarter 

building. 

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RITZHEIMER 

28. RITZHEIMER appeared in a video titled "Militants take to social media to recruit 

supports," posted on January 4, 2016, to an Internet website and stated, "We are in my truck 

parked outside the Refuge," "We need you to get here and stand with us," "whether you are 

armed or unarmed," and "Please get up here to help us." Another person also appeared in the 

video stating, "We need your help guys." RITZHEIMER also posted a video where he stated, 

"I've had to do a lot of soul searching up here, and I am with good people who also have had to 

do a lot of soul searching, some who've done this soul searching for years, and I am one hundred 

percent willing to lay my life down, to fight against tyranny in this country." A photo posted on 

an Internet news website shows RITZHEIMER adjusting a sign outside the MNWR on 

January 5, 2016, shown below. A Federal Wildlife Officer with the U.S. Fish and Wildlife 

Service has confirmed the location of the signs on the MNWR close to the main entrance. 

Tyr•an • ny i cruel, 

unrea onable, arbitrary u of 

Power or Control 

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29. On January 5, 2016, in a video taken by SANTILLI and posted to YouTube, 

RITZHEIMER states "last word we got is they're headed out here" in reference to the armed 

occupiers who believed they were going to be raided by the federal government. RITZHEIMER 

further states, "We got word that they're coming out here, uh so we are trying to plan and 

maintain a defensive posture" and "Right now underneath that tarp right there- Lavoy Finicum 

is sitting underneath that tarp, and he is not going to let them come through. We're maintaining 

a defensive posture back here." In the still shot below, RITZHEIMER is carrying what appears 

to be, based on my training, experience and knowledge of firearms, an AR-15-style rifle with 

sling. 

O'SHAUGHNESSY 

30. A video entitled "#aslongasittakes" was live-streamed starting January 5, 2016, 

continuing into January 6, 2016, and posted on YouTube to the "Pete Santilli Show." The video 

is filmed at or just outside the MNWR. The location of the video outside the MNWR was 

confirmed by a Federal Wildlife Officer. In the video, O'SHAUGHNESSY was interviewed by 

SANTILLI and states, "We have people here that are standing up for the constitution," "We need 

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every patriot in this country to come out here and and support the message," "You guys need to 

be out here to show your support you need to stop the bickering," and "If you want to lock arms 

in front of this reserve and make sure that these federal agents and this corrupt government 

doesn't come through those gates, you can do that. Or if you want to go on in and do what you 

gotta do then go on and do that, everybody has a place in this and everybody need to be here." 

O'SHAUGHNESSY further states in the interview, "I'm right now in the process of trying to set 

up a constitutional security protection force to make sure that these federal agents and these law 

enforcement don't just come in here like cowboys, that's we have to prevent that um." 

PAYNE 

31. PAYNE arrived to Hamey County in November 2015. In one public source email 

dated November 20, 2015, posted by a user using email address rypaynel@xxx.com with the 

user name "Ryan Payne," PAYNE was encouraging others to support him in planning a response 

to Hamey County, and wrote: 

The opportunity to defend the Hammonds is not the first, nor will it be the 

last. But the display of tyranny in this particular case is so appalling, the people 

being directly subjected to it so undeserving, and the oppressive weight so heavily 

and completely applied; upon not only the Hammonds, but their entire 

community; that to decide to allow it to persist should trouble the soul such that 

death might be a welcome relief. 

We must be wise, and great discernment must guide our decisions, 

particularly when we ask that others be willing to shed their blood alongside us. 

We must choose our engagements with great care and consideration for the lives 

of all involved, on all sides. The situation calling out to us now is such that to not 

heed it's [sic] cries will be a betrayal of the very foundation and principles we 

have built our convictions on, and reduce them to empty claims. 

32. On November 22, 2015, a second email was posted by the same user as above 

stating: "I have made my decision. I spoke with those that I began this endeavor with, well 

before OMD came to be, and we agreed that the people must be given an example, and that this 

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is what we sought to provide. Perhaps the example I provide is such to educate them, whether as 

a leader, or as to what they should not do. Only God can determine such things." 

33. On January 5, 2016, PAYNE was contacted by Bums Police Department at a 

McDonalds in Harney County, Oregon. PAYNE was with a second individual at the time of 

contact and both individuals were armed. An officer's body camera captured the event and a still 

image from the contact is shown, below. PAYNE is the individual on the left, with a visible 

holster on his hip. 

34. The photo below depicts PAYNE at the MNWR. A staff member of the U.S. Fish 

and Wildlife Service who works at the MNWR, has confirmed the photo depicts the interior of 

the RV park common room, a building located inside the MNWR. PAYNE has been positively 

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identified by law enforcement through motor vehicle records and open source information, 

including Internet sharing websites. 

35. On January 4, 2016, a national news organization posted a video online of 

A. BUNDY delivering a press conference. A screenshot from that video appears below. The 

screenshot depicts, from left to right, CAVALIER, A. BUNDY, PAYNE, and other known and 

unknown individuals. This photograph has been verified by a Federal Wildlife Officer with the 

U.S. Fish and Wildlife Service to depict the MNWR's headquarter tower in the background. 

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Given the proximity of the tower to the individuals, the individuals are likely standing close to 

the Refuge entrance sign on the entrance road. 

R.BUNDY 

36. On January 6, 2016, R. BUNDY was photographed by a national news reporter 

inside an MNWR building with A. BUNDY. The location of the photograph inside a U.S. Fish 

and Wildlife biologist's office in a federal building on the MNWR was confirmed by a Federal 

Wildlife Officer of the U.S. Fish and Wildlife Service. This photograph was posted to a national 

Internet news website. The photo clearly shows R. BUNDY carrying a rifle while A. BUNDY is 

on the phone, as shown below: 

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CAVALIER 

37. CAVALIER, who uses the handle "Booda Bear," posted a video to an Internet 

website channel on September 9, 2015, in which he stated, "I am Cliven and Carol's and the 

family's personal body guard." 1 As recently as January 4, 2016, he can be seen standing next to 

and escorting A. BUNDY during press conferences, as seen in the below screen shot 

(CAVALIER is the individual on the left). According to a Federal Wildlife Officer with the U.S. 

Fish and Wildlife Service, the photo depicts A. BUNDY at the main entrance and the trees in the 

background surround the main headquarter building. Sometime after January 4 and before 

January 11 , 2016, CAVALIER left the MNWR. CAVALIER was arrested on January 11 , 2016, 

by the Buckeye Police Department in Arizona. He had outstanding warrants from Prescott and 

Prescott Valley, in Arizona. CAVALIER was in possession of a firearm at the time of his arrest. 

After his arrest, he was released and returned to Hamey County. 

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1 Cliven and Carol Bundy are the parents of A. BUNDY and R. BUNDY. 

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Finicum 

38. In a local news report dated January 5, 2016, located online, Finicum spoke to 

reporters at the MNWR. Finicum was interviewed on video outside the Refuge wrapped in a 

tarp and blanket. He stated, "There are things more important than your life and freedom is one 

of them. I'm prepared to defend freedom. " Finicum was reported as holding a rifle and 

backpack and was staying at the entrance to the Refuge overnight. A. BUNDY, identified as a 

group leader, said the group would take a defensive position as they were anticipating a possible 

raid. In a later video posted on January 6, 2016, the speaker states, "There was intel that the uh, 

um, camp was going to be raided. " He then shows the heavy equipment which was placed to 

barricade the road and stop the "feds." He then states the equipment was brought up for them to 

"defend themselves." A photo accompanying the local news article and captioned "Activists 

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have used heavy equipment to block to the road to the Malheur wildlife refuge buildings" is 

shown below. A Federal Wildlife Officer with the U.S. Fish and Wildlife Service identified the 

equipment in the photograph as an MNWR loader and grader blocking the main entrance. 

39. A photo shown below from a local news station posted online on January 6, 2016, 

shows Finicum carrying a rifle at the MNWR. The location ofFinicum at the main entrance of 

the MNWR was confirmed by a Federal Wildlife Officer of the U.S. Fish and Wildlife Service. 

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cox 

40. On January 4, 2016, a video was posted to an Internet website titled "Citizens for 

Constitutional Freedom News Conference Oregon 1-4-16(1)." In the video, A. BUNDY 

introduces COX who identifies herself and spells her name. COX speaks as a representative of 

the "Citizens for Constitutional Freedom" and other participating groups, including Bundy 

Family and Supporters, Liberty for All, Oregon Bearded Bastards, Pacific Patriot Network, and 

Liberty Watch Washington. A screenshot from the video is shown below: 

41. On January 6, 2016, COX was photographed with A. BUNDY inside a building at 

the MNWR. The photo was posted online to a national news website with the caption "Ammon 

Bundy (L), and supporter Shawna Cox work in an office at the Malheur National Wildlife 

Refuge." A Federal Wildlife Officer with the U.S. Fish and Wildlife Service confirmed the 

photo depicts the inside a U.S. Fish and Wildlife biologist's office in a federal building on the 

MNWR. 

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SANTILLI 

42. Law enforcement became aware SANTILLI has been in Hamey County, Oregon, 

since January 2, 2016, but the exact date of his arrival in the area is unknown. SANTILLI 

operates a channel on YouTube called "Pete Santilli Show." Details of the channel indicate it is 

categorized as entertainment under a standard license for Y ouTube. SANTILLI has posted video 

to the channel concerning the Hammond family and has been calling for people to come to 

Oregon since at least December 27, 2015. SANTILLI often streams live video from his 

Y ouTube channel. All video referred to in this affidavit has been preserved by law enforcement 

agents. In the referenced videos, SANTILLI often wears a vest which says "PRESS" with his 

name below it. SANTILLI has identified himself as a member of the Oath Keepers and wears 

insignia which indicates his affiliation with the III% group, detailed below. According to open 

source information, the Oath Keepers and III%ers have been identified as organizations 

associated with the anti-government patriot movement. 

43. On December 27, 2015, a video was posted on SANTILLI's YouTube channel 

"Pete Santilli Show" titled "Operation Hammond Ranch - Patriot ALL-CALL Deployment to 

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Oregon." In the video, SANTILLI mentions known armed occupiers RITZHEIMER and 

O'SHAUGHNESSY and states they have "put out an all call for all patriots to respond. It was a 

call to action, all patriots to respond no later than January 2 to Oregon." SANTILLI also states: 

There's going to be a lot of updates coming, ok. Ah, a lot of stuff that's going to 

be happening out there, I can't go into the exact details, because a, I don't have all 

the details. I ah, I, let's call it, um, I'm not a, I need to be on a need to know 

basis. I'm going to be, as a member of the media, ah, exercising my First 

Amendment rights to cover this stuff for the American public cause the main 

stream media is not going to be bringing you what we are going to be bring to, 

bringing you as to what's happening, ah, at Hammond Ranch. So, ah, we are 

calling it initially here Operation Hammond Ranch. That may change, ah, but we 

want to bring awareness to Hammond Ranch. 

SANTILLI continued in the video by stating: 

What it's about, it's in Oregon, ah, and we need you to get out there, ah, this is an 

all call, ah, it's been green lighted, for all patriots to respond to Oregon on or 

before January 2, ah there's going to be a patriot convoy on January 2. You'll be 

getting those exact details. So I'm Pete Santilli. Be sure to like, comment, 

subscribe, and share the heck outta this thing. Get the word out, ah, to all patriots 

that can get out there, especially in the Pacific Northwest. Ah, you must get out 

there, ah what is happening here .... 

SANTILLI continues: 

Ok, ah, we got the Federal government running around as if they're trying to 

protect us from terrorism. No, they're trying to shut down patriots like me, 

Schuyler Barbeau, throw them in jail, throw the Hammonds in jail, call them 

terrorists, and, ah, let all the Syrian refugees come in. We're not going to let it 

happen. We're going to take a stand . .. . Ok, I'm sure they had original 

intentions to be extremely peaceful. Ah, of course, ah, we, ah, we must get the 

Federal government to comply with our peaceful demands, ah, otherwise we have 

to explore all opportunities that we have made available to us through our 

founding fathers. So, ah, um, be prepared, be alert, um, and definitely respond to 

this call of action, call to action folks, all call, all patriots get out there. Thank 

you. Alright, here we are. 

44. On January 2, 2016, a video was posted on YouTube channel "Pete Santilli 

Show" titled " [Live feed 2] Operation Hammond Ranch." The video appeared to be filmed in 

the parking lot of the Safeway grocery store in Burns, Oregon, prior to a scheduled protest at 

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noon the same day. In the video, SANTILLI states, "Hey ladies and gentlemen, I just want you 

guys to know, I want it stated for the record here on the Pete Santilli Show." SANTILLI then 

turns and faces the camera directly and states: "Hey Stewart Rhodes, I tore up my membership 

card. I'm still an Oath Keeper, homey, huh, how does that work? I don't need your card. I 

don't need to pay your membership dues." SANTILLI then turns away from camera and 

addresses others and says: "I tore up my card. I tore up my card. I tore up my card. I'm still an 

Oath Keeper. See how that works?" SANTILLI then turns back to camera and says: "You know 

what, sue me. I got nothing. I got a freaking, I got an ash tray and a freaking pocket a hole. 

That's it. Sue me. Sue me. I'm an Oath Keeper. Can you imagine that? I tore up my card. I 

didn't blow up. It's amazing." 

45. On January 2, 2016, a video was posted to YouTube channel "Pete Santilli Show" 

titled "Live feed Hammond ranch." The following conversation was heard on video but took 

place off-camera: 

Ammon BUNDY: Hey we're continuing the stand. We're continuing the stand 

[at/out] the MNWR. 

SANTILLI: Ok. 

Ammon BUNDY: Let everybody know that. 

SANTILLI: Ok. 

Ammon BUNDY: They're to go to the MNWR ... [inaudible] .. . after the rally 

. .. MNWR right after. 

SANTILLI: [Coming back on microphone]: Ok, here we go ... . [Returns to 

protest]. 

Also captured in the same video, an unidentified male greets A. BUNDY, and states he was with 

A. BUNDY in Nevada. The following conversation was then captured on video: 

II I 

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Ammon BUNDY: We're continue the stand ... [becomes inaudible as 

SANTILLI's cameraman moves away, and bumps into someone]. 

Cameraman: I was trying to get away from that conversation. 

Below is a still frame shot from the above conversation as A. BUNDY speaks to the unidentified 

man. 

46. Later, on the same video, the camera pans back as A. BUNDY leans in to 

SANTILLI and says, "Malheur, Malheur." The below still shot captures the moment 

A. BUNDY is talking to SANTILLI (SANTILLI is facing away from camera with mesh vest and 

black baseball cap). SANTILLI appears to acknowledge A. BUNDY and then pulls A. BUNDY 

in for a public speech on SANTILLI's live stream. 

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47. On January 5, 2016, a video was posted on YouTube channel "Pete Santilli 

Show" titled "Live update Burns Oregon #aslongasittakes." In the video, SANTILLI states: "We 

want a constitutional sheriff, constitutional peace officers, but here is what we need, most 

importantly, ok, this is what we need, now I'm gonna say this and I am going to be talking about 

it throughout the day: one hundred thousand, unarmed, men and women, to stand together. It is 

the most powerful weapon in our arsenal, those guns that we were talking about, those that were 

carrying guns .... " SANTILLI then talks to a gas station attendant and repeats the same call for 

one hundred thousand people. 

48. Also on January 5, 2016, a video entitled "#aslongasittakes" was live-streamed 

for several hours. The video started on January 5, 2016, continued into January 6, 2016, and was 

posted on Y ouTube channel "Pete Santilli Show." The video is filmed at or just outside the 

MNWR. The location of the video outside the MNWR was confirmed by a Federal Wildlife 

Officer of the U.S. Fish and Wildlife Service. During the video, SANTILLI stated, "We,'re not 

fucking going nowhere." SANTILLI later stated, "Here is what we need. I'm gonna tell you 

something right now. Captain Joe, myself, I'm not armed. I am armed with my mouth. I'm 

armed with my live stream. I'm armed with a coalition of like-minded individuals who sit at 

home and on YouTube and watch this." 

49. On January 6, 2016, a video was posted on YouTube channel "Pete Santilli 

Show" titled "press conference." In the video, SANTILLI states, "We need to join together, one 

hundred thousand, unarmed men and women, one hundred thousand of them, whether they be 

from the outside, or they be from here in this local county." 

Ill 

Il l 

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50. On January 7, 2016, a video was posted on YouTube channel "Pete Santilli 

Show" titled "Live From Burns, Oregon - #aslongasittakesoregon." In the video, SANTILLI 

states: 

I want one hundred thousand people out here, shoulder to shoulder, uh, unarmed. 

That's what I am calling for. Out here, between, and and to learn, ok, and to also 

protect the good souls that are inside, uh, if the Sheriffs department is telling you 

not to come out here, ok, uh, that means that they are trying to keep you away 

from the truth .... Ok, this learning experience that is going to take place here in 

the coming days, you guys are going to be blown away as this thing starts to 

unravel, uh, but you need to come out here, ok, you need to come out and not 

cower in fear .... 

51. On January 11 , 2016, a video was posted on YouTube channel "Pete Santilli 

Show" titled "Burns, Oregon- Community Meeting @ Burns High School." In the video, 

SANTILLI can be seen wearing III% on the sleeve of his shirt, shown below. 

52. On January 12, 2016, a video was posted to Y ouTube channel "Pete Santilli 

Show" titled " 1/12116 Day 11 - Update [l] from Malheur Wildlife Refuge in Burns, Oregon -

#OregonFront." In the video, SANTILLI states: 

II I 

Ill 

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I give you my word from this point forward, I will be lawful, I will be 

constitutional, ok, but I want to stand with you shoulder to shoulder, in 

opposition to what is happening here in Bums, and I want to crush 

communism here in Bums, and I want to crush socialism here in Bums, and 

I want to call upon everyone, if we can get one hundred thousand people 

standing shoulder to shoulder with me with flowers and determination, to 

take a stand against what's happening here in Burns. I want you to join me 

at this meeting. Please join me at this next meeting. Please. I'm going to 

go .... 

53. On January 17, 2016, a video was posted to an Internet video sharing website by 

user "Veritas 13 Fox" titled "Press Brief, FBI Cam#, & Calling BS on ABC News." In the video 

SANTILLI can be seen standing behind Finicum, with RITZHEIMER and another occupier, at 

the main entrance to the MNWR. The vest SANTILLI is wearing has a clearly visible Oath 

Keeper patch on front. The vest also reads "PRESS" on the back. The video depicts that just 

prior to the press conference, SANTILLI whispered something in Finicum's ear and patted him 

on the back. After Finicum stated that the property does not go back to the BLM and then stated, 

"It does not return to the federal government," SANTILLI put his arm around the individual 

standing next to him. After Finicum spoke, SANTILLI addressed the media and said: 

LaVoy's ah, offered me the opportunity to come up and speak to the members of 

the press. Uh, my name is Pete Santilli, uh for those of you that don't know me, 

uh I've accumulated approximately fifteen million uh minutes of viewing time, on 

the stream total combined uh worldwide, and I want to uh let the main stream 

media know uh that those that are not watching the stream or haven't been tuned 

in to my show, shame on each and every one of you. For those people that have 

been following the main stream media ... [inaudible] ... still asking the question. 

After twelve, thirteen days of being out here people are still wondering what the 

core issues are here, on this land. Shame on each and every one of you, millions 

of dollars being spent, you have an obligation to communicate to the public, and 

unfortunately your filtering [inaudible] ... the public is not well informed. 

A screen shot of the video is shown below: 

II I 

I l l 

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54. On January 21, 2016, a video was posted to YouTube channel "Pete Santilli 

Show" titled "BREAKING: Ammon Bundy Meets & Negotiates With FBI [EXCLUSIVE]." In 

the video, A. BUNDY can be seen and heard speaking with FBI personnel over a speaker on a 

cell phone. CAVALIER is standing beside A. BUNDY. SANTILLI introduced himself to 

several people as he filmed what was going on. Approximately thirteen minutes after leaving the 

meeting and while driving away, SANTILLI had the following conversation with a second 

person in his vehicle, who is off-screen, operating the video camera: 

Camera person: They're amping up their uh little camp there. You know they are 

building, they have built a uh very large triage in the hospital. We have, we've 

confirmed that, we have, and we've also noticed in the last week that they're 

starting to uh get closer and closer to the refuge. 

SANTILLI: Can I say something? Can I add something? 

Camera person: Well of course. 

SANTILLI: This is what I wanna tell, and good patriots will do good things, 

that's what I'm calling for. All you good patriots out there, it's time to staff up. 

Ok. 

Camera person: Staff up? Yes. 

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SANTILLI: I'm gonna say this right now, loud and clear, and I want to put it out 

to every one of you patriots out there right now. This is to provoke 

constitutionality, ok, only! That's it. So don't say 'oh my goodness lo lo lo, shut 

your cake hole!' If you're a patriot, ok, and and you believe in what we're doing 

here as to ah protecting our god given rights, ok, you need to get in your car and 

come out here ok. Good patriots will do good things. Now's the time, time to 

staff up, ok. Time to staff up. I, I saw a compound that is so [video skips] ... 

alright, that's what I'm calling for, that's what I'm provoking here, alright! Uh, 

we have a Second Amendment right uh to do that, to keep and bear arms. So 

those patriots that do keep and bear arms lawfully and constitutionally, it's time to 

staff up now! Right now. 

55. In addition to social media posts made by individuals noted above, multiple news 

reports, interviews, and videos have reported or shown th.e occupiers of the MNWR to be armed 

with pistols and long guns. 

56. On January 26, 2016, A. BUNDY, O'SHAUGHNESSY, PAYNE, R. BUNDY, 

CAVALIER, COX, and SANTILLI were taken into custody. 

Conclusion 

57. This affidavit and the requested arrest warrants were all reviewed by two 

Assistant United States Attorneys (AUSAs) prior to being submitted to the Court. The AUSAs 

informed me that in their opinion, the affidavit is legally and factually sufficient to establish 

probable cause to support the issuance of the requested warrants. I respectfully request the Court 

to authorize the proposed arrest warrants based on this complaint. 

~~h

Federal 

Special 

THERINE 

Agent 

Bureau 

ARMSTRN 

oflnvestigation 

~ 

Subscribed and sworn to before me this cJ~f', day of January 2016. 

Affidavit of Katherine Armstrong 

THONLE STACIE F. BECKERMAN 

U.S. Magistrate Judge, District of Oregon 

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