.. 

Stephen R. Sady, OSB #81099 

Chief Deputy Federal Defender 

Email: steve _ sady@fd.org 

Susan F. Wilk 

Assistant Federal Public Defender 

Email: susan _ wilk@fd.org 

101 SW Main Street, Suite 1700 

Portland, OR 97204 

Tel: (503) 326-2123 

Fax: (503) 326-5524 

FILED 6 APR '17 9 :201.JSDC~ 

IN THE UNITED STATES DISTRICT COURT 

IN RE GARY HUNT, 

FOR THE DISTRICT OF OREGON 

PORTLAND DIVISION 

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

MOTION FOR REVOCATION OF 

DETENTION ORDER 

The defendant, through his appointed counsel, Assistant Federal Public Defender Douglas 

Beevers of the Eastern District of California, with the assistance of Chief Deputy Federal Public 

Defender Stephen Sady of Oregon Federal Public Defender's office, respectfully moves this Court 

pursuant to 18 U.S.C. § 3145(b) for an order revoking the detention order entered in the Eastern 

District of California on March 31, 2017, in United States v. Hunt, 2:17-mj-00058-EFB, on the 

grounds that conditions can be fashioned to assure Gary Hunt's appearance in this Court as directed 

and that there are no issues of public safety in this case. 

Page 1 MOTION FOR REVOCATION OF DETENTION ORDER 
Mr. Hunt was arrested based on a warrant from the District of Oregon with failing to 

respond to an Order to show cause in a context involving significant issues of jurisdiction and the 

First Amendment. See United States v. Patrick, et al., No. 3:16-cr-000512-BR, docket entry 2017 

(filed Mar. 10, 2017). After he was arrested in California, he attempted to be interviewed by the 

Pretrial Services Office but, apparently because the matter was not clearly criminal, no interview 

was conducted. Mr. Hunt is a 71-year-old Vietnam veteran who is a retired professional surveyor. 

He has no prior criminal history and has stable long-term connections to his community, including 

residence in the same house for 14 years. He has represented and continues to represent to the 

Court that he will comply with the requirement that he appear in Portland, Oregon, for his 

appearance in federal court. 

Prior to his first appearance in California, Mr. Hunt did not have the advice of counsel 

regarding this matter. Now that he has representation, he intends to work with counsel to assert his 

legal positions that question the authority of the government to proceed against him and that assert 

the full range of applicable constitutional and statutory protections on individual rights. He 

understands through his California counsel that the Oregon office of the Federal Public Defender 

represents a defendant in the underlying Bundy case and may have a conflict. He further 

understands that the assistance of the Oregon Federal Public Defender's office is limited to urgent 

preliminary matters in furtherance of his release and his request for appointment of conflict-free 

counsel to act as his attorney under the Criminal Justice Act for future representation. 

On the basis of the foregoing, Mr. Hunt respectfully requests that the Court revoke the 

detention order and order him immediately released on his own recognizance or on conditions. 

Page 2 MOTION FOR REVOCATION OF DETENTION ORDER 
Pursuant to § 3145(b ), he requests that "the motion shall be determined promptly." The 

government, through AUSA Pamala Holsinger, opposes this motion. 

Respectfully submitted this 6th day of ti!, 2017. 

~~+-~~__..,~~--t-~~~~~~-

S t e p hen R. Sady 

Chief Deputy Federal D fender 

Susan F. Wilk 

Assistant Federal Publ" Defender 

Page 3 MOTION FOR REVOCATION OF DETENTION ORDER 

I 

I 

I 

~ i 

I 

! 

i 

I 

i 

f; 

~ 

I 

t 

,_ f 

~ 

f