BILLY J. WILLIAMS 

United States Attorney 

District of Oregon 

ETHAN D. KNIGHT, OSB #992984 

GEOFFREY A. BARROW 

CRAIG J. GABRIEL, OSB #012571 

PAMALA R. HOLSINGER 

Assistant United States Attorney 

1000 SW Third Ave., Suite 600 

Portland, OR 97204-2902 

Telephone: (503) 727-1000 

Attorneys for United States of America 

IN THE UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

UNITED STATES OF AMERICA 

v. 

AMMON BUNDY, et al., 

Defendants. 

STATE OF OREGON 

County of Multnomah 

3:16-CR-00051-BR 

AFFIDAVIT OF FBI SPECIAL AGENT 

RONNIE WALKER IN SUPPORT 

OF MOTION TO ENFORCE 

PROTECTIVE ORDER 

(EXPEDITED CONSIDERATION REQUESTED) 

) 

) ss. 

) 

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 a motion to enforce a protective order. 

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 

Affidavit of FBI SA Walker Page 1 

Case 3:16-cr-00051-BR Document 1681 Filed 01/06/17 Page 1 of 11
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 CA VALIER, 

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 Malheur National Wildlife Refuge (MNWR). 

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 3 72. 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 ); with 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 of America v. 

Ammon Bundy, et al., was assigned case number 3: l 6-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 

Affidavit of FBI SA Walker Page 2 

Case 3:16-cr-00051-BR Document 1681 Filed 01/06/17 Page 2 of 11
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 

further 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 whom defense 

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

I 0. 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. A copy of the final Protective Order, court 

record 342, is attached to this application. 

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

lower left hand column "Dissemination Limited by Court Order" and was marked in the lower 

right hand comer with a Bates number in the following format: "MNWR _ 000000." The entire 

discovery production was marked from MNWR _ 0000001 to MNWR _ 006964 7. The discovery 

documents were primarily provided in Portable Document Format, commonly referred to as 

PDF. Because PDF documents that contain text are not text-searchable, the discovery materials 

were also converted into a second format using Optical Character Recognition or OCR. The text 

document that comes as an output from the OCR conversion can be copied on to any word or 

text processing application. 

12. Volume 41 of discovery was provided to defense counsel on or about July 1, 

Affidavit of FBI SA Walker Page 3 

Case 3:16-cr-00051-BR Document 1681 Filed 01/06/17 Page 3 of 11
2016. Contained in Volume 41 were 130 FBI reports containing Confidential Human Source 

(CHS) information and the majority were reports completed on FBI form FD-1023. Based on 

my training and experience, I know that Form FD-I 023 is the original reporting document for 

information provided to FBI Agents by a CHS. These reports document statements by witnesses 

to government officials as described in the final Protective Order. The 130 reports consisted of 

246 pages and will collectively be referred to as the "CHS Discovery" for this affidavit. All 

discovery materials, to include each of the CHS Discovery reports, were marked "Dissemination 

Limited by Court Order." The Bates numbers for the CHS Discovery reports were from 

MNWR_0059420 to MNWR_0059665. Each report contained areas which were redacted by the 

government. 

13. 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 plead guilty. A second trial for the 

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

14. On November 5, 2016, an article titled "Bums Chronicles No 39 - Informants -

What to do About them" was posted on the Outpost of Freedom blog at http://outpost-offreedom.com. The home page for the aforementioned website was titled "the Outpost of 

Freedom by Gary Hunt." This article addressed how the patriot community should deal with 

three informants identified during the first trial. 

15. On January 28, 2016, an officer of the Bums Police Department (BPD), Bums, 

Oregon, made contact with a white adult male at the Silver Spur Motel, Bums, Oregon. This 

police contact was video recorded by the officers. During the contact, the BPD officer asked the 

individual for identification. This individual provided a business card which stated "Gary Hunt, 

Outpost of Freedom" and provided his address as 25370 2nd Avenue, Los Molinos, California. 

16. I have spoken with Special Agent Matthew Catalano of the FBI Sacramento 

Division who has reviewed the above described BPD video. According to Special Agent 

Catalano the individual depicted in the above described police video was Gary HUNT, a white 

Affidavit of FBI SA Walker Page 4 

Case 3:16-cr-00051-BR Document 1681 Filed 01/06/17 Page 4 of 11
male, 70 years of age, who resides at 25370 2nd Avenue, Los Molinos, California. 

17. The "About Gary Hunt" page at http://outpost-of-freedom.com/blog states: 

Gary Hunt was a Professional Land Surveyor. Having been the County Surveyor 

for Orange County, Florida from 1974 to 1978, he began private practice in 1978 

and continued as such until 1993, when events in Waco, Texas caused him to 

leave his business in pursuit of restoring the Constitution. 

In 1989, he began researching, investigating and studying history, law and events 

where the government was 'pointing it's guns in the wrong direction'. He began 

publishing a patriot newspaper, "Outpost of Freedom", in February 1993. 

Since that time, he has investigated numerous occurrences, including, Waco, the 

Murder of Michael Hill, Ohio Militia Chaplain, Oklahoma City Bombing, and 

other events. He has attended the sites to investigate the events, and has reported 

on his investigations. 

He also writes articles about history, the government's misdeeds, and, other 

subjects appropriate to the Patriot community. He has continued to report on his 

findings through fax networking and the Internet. 

18. On November 15, 2016, an article by HUNT titled, "Bums Chronicles No 40" 

was posted on the Outpost of Freedom blog at http://outpost-of-freedom.com. This article 

alleges that AV was an FBI CHS and draws conclusions based on facts provided in the CHS 

Discovery. One passage of Burns Chronicles No 40 states the following: 

Let's get to the heart of the matter. To do so, I will be referring to FBI documents 

that I have obtained. They are marked, at the bottom left comer, "Dissemination 

Limited by Court Order". So, let me make this perfectly clear- I have no 

intention of "disseminating" the documents, nor am I bound by any "Court 

Order". I am writing about a Public Trial, which was held in September and 

October 2016. Had I access to these documents during that trial, I would have 

written the same article that I am writing now. 

19. In paragraph 18, and all subsequent paragraphs, I have used the initials of the 

individuals HUNT alleges were FBI informants to protect those who may have been correctly 

identified by HUNT as well as those individuals who may have been incorrectly identified by 

HUNT. Based on my experience with this investigation, I know some of the defendants in this 

case and individuals associated with the defendants in this case have advocated for violence 

against federal employees, law enforcement, and/or informants. For example, following his 

Affidavit of FBI SA Walker Page 5 

Case 3:16-cr-00051-BR Document 1681 Filed 01/06/17 Page 5 of 11
arrest on January 27, 2016, a digital camera was seized from Jason PATRICK. Pursuant to a 

District of Oregon, federal search warrant, the contents of the camera were searched. One video 

located on the camera depicted a group meeting at the MNWR subsequent to the arrest of 

Ammon BUNDY and others on January 26, 2016. During this meeting an individual stated to 

the group "(Let's) regroup, get in, go find out who works for the Feds and start executing them. 

Execute them, their families, everyone. Make it a statement. If you work for those crooked 

fucks you're going to die." 

20. Throughout Burns Chronicles No 40, HUNT published excerpts from five 

separate FD-I 023 reports which were issued in the CHS Discovery as MNWR _ 0059420, 

MNWR_0059421, MNWR_59422, MNWR_0059424, MNWR_59426, MNWR_59429, 

MNWR_59433 and MNWR_0059434. I have reviewed HUNT's article and the eight pages 

from the five FD-I 023 reports which Hunt quoted and observed the quoted excerpts to be nearly 

identical to the text in the CHS Discovery in nearly all instances. One passage which was 

published by HUNT from MNWR _ 0059424 states: "Most individuals are carrying side arms 

and CHS has not seen any Iongrifles (sic), but knows they are there." I have reviewed the CHS 

Discovery and observed the PDF ofthe original FD-1023 to correctly use "long rifles" in this 

passage. I also reviewed the OCR output and observed that "Iongrifles" was the text conversion 

produced by the computer software. Based on this and other similar examples in HUNT's posts, 

I believe HUNT received both the PDF and OCR versions of discovery and HUNT is using a 

copy and paste function to distribute selected excerpts from discovery. 

21. On November 16, 2016, an article by HUNT titled "Burns Chronicles No 41" was 

posted on the Outpost of Freedom blog at http://outpost-of-freedom.com. This article alleges 

that DD was an FBI CHS and draws conclusions based on three FD-1023 reports provided in the 

CHS Discovery. I have reviewed the CHS Discovery and observed the excerpts published by 

Hunt match reports which were issued in discovery as MNWR_0059469, MNWR_0059472, 

MNWR_0059474, MNWR_0059475, and MNWR_0059476. These CHS Discovery reports 

primarily discuss meetings conducted by a group of individuals self-identified as the Operation 

Affidavit of FBI SA Walker Page 6 

Case 3:16-cr-00051-BR Document 1681 Filed 01/06/17 Page 6 of 11
Mutual Defense (OMD) Advisory Board (AB). 

22. According to Bums Chronicle No 41, the OMD-AB was comprised of five 

members including Gary HUNT and Ryan PAYNE and the AB members had agreed to record 

the telephonic meetings which were then placed in a Dropbox folder. According to Bums 

Chronicle No 41, HUNT "had set up the Dropbox account and the mail-list group. The Dropbox 

is rather simple where only designated people have access and large files can be transferred up 

and down in the background." 

23. Near the conclusion of Bums Chronicles No 41, Hunt states the following: "As 

we continue through the documents, DD reports every detail of any possible action. Basically, 

he provided the minutes that he declined to prepare for the OMD-AB. He has 20 known and 

more possible reports. Those 20 constitute 41 pages of the 230 pages of 1023 reports. He is, 

perhaps, the most prolific writer of the informants." 

24. Also included in Bums Chronicles No 41 is an excerpt from an internal FBI 

document which was provided in discovery Volume 23, MNWR_0030175 and 

MNWR 0030176. This internal document was utilized to submit evidence to FBI evidence 

control related to CHS activities. 

25. On November 20, 2016, an article by HUNT titled "Bums Chronicles No 42" was 

posted on the Outpost of Freedom blog at http://outpost-of-freedom.com. This article addresses 

the October 2016 testimony of an FBI CHS and cites information provided in the CHS 

Discovery. I have reviewed the CHS Discovery and observed the information published by Hunt 

to match four FD-1023 reports which were issued in CHS Discovery as MNWR _ 0059460, 

MNWR_0059461, MWNR_0059462, MNWR_0059463, and MNWR_0059465. 

26. On November 22, 2016, an article by HUNT titled "Bums Chronicles No 43" was 

posted on the Outpost of Freedom blog at http://outpost-of-freedom.com. This article addresses 

the testimony of an individual who identified herself as an FBI CHS during the 

September/October 2016 trial. I have reviewed the CHS Discovery and observed the 

information published by Hunt to match four FD-1023 reports which were issued in the CHS 

Affidavit of FBI SA Walker Page 7 

Case 3:16-cr-00051-BR Document 1681 Filed 01/06/17 Page 7 of 11
Discovery as MNWR_0059637, MNWR_0059638, MNWR_59640, and MNWR_0059644. 

27. In Bums Chronicles No 43, HUNT also published an un-redacted FD-1023 that 

was inadvertently published in Volume 15 of discovery as MNWR _ 26498 on or about May 26, 

2016. This un-redacted FD-1023 was the same report later published in Volume 41 as 

MNWR_0059638. HUNT published images of both reports side by side to illustrate the 

redaction process. Based on this fact, and other references in HUNT' s posts such as those 

detailed in paragraph 24 above, I believe HUNT received not just Volume 41 's CHS Discovery 

materials, but the entire production of discovery provided in this investigation in violation of the 

terms of the final Protective Order. 

28. On November 25, 2016, an article by HUNT titled "Bums Chronicles No 44" was 

posted on the Outpost of Freedom blog at http://outpost-of-freedom.com. This article details 

HUNT' s investigation into MM, a CHS identified in the September/October 2016 trial and cites 

information provided in twelve CHS Discovery reports. In this article, HUNT states: "When I 

obtained access to the CHS Reporting Documents (form 1023), it was simply a matter of 

matching dates, statement, etc., to determine which of those reports were from MM. This 

required communication with those who were at the Refuge, though not still in custody, to verify 

certain things that became key to unlocking the necessary proof of MM's role as an informant." 

I have reviewed the CHS Discovery and observed the information published by Hunt to exactly 

match twelve FD-1023 reports which were issued in the CHS Discovery as MNWR_0059605, 

MNWR_0059607,MNWR_0059609,MNWR_0059612,MNWR_0059613,MNWR_0059615, 

MNWR_0059616,MNWR_0059617,MNWR_0059620,MNWR_0059621,MNWR_0059624, 

MNWR_0059625, MNWR_0059627, and MNWR_0059629. 

29. On December 19, 2016, an article by HUNT titled "Bums Chronicles No 47" was 

posted on the Outpost of Freedom blog at http://outpost-of-freedom.com. This article alleges RS 

was an FBI informant and publishes information from approximately thirteen CHS Discovery 

reports. I have reviewed the CHS Discovery and observed the information published by Hunt to 

exactly match FD-1023 reports which were issued in the CHS Discovery as MNWR 0059520, 

Affidavit of FBI SA Walker Page 8 

Case 3:16-cr-00051-BR Document 1681 Filed 01/06/17 Page 8 of 11
l\1N\VR_0059524,.rv1N\VR_0059526,l\1N\VR_0059527,l\1N\VR_0059529,l\1N\VR_0059530, 

l\1N\VR_0059533,l\1N\VR_0059534,.rv1N\VR_0059535,.rv1N\VR_0059537,l\1N\VR_0059540, 

l\1N\VR_0059544, l\1N\VR_0059546, l\1N\VR_0059547, and l\1N\VR_0059554. 

30. On December 22, 2016, an article by HUNT titled "Bums Chronicles No 49" was 

posted on the Outpost of Freedom blog at http://outpost-of-freedom.com. This article alleges TD 

was an FBI informant and publishes information from several CHS Discovery reports. I have 

reviewed the CHS Discovery and observed the information published by Hunt to exactly match 

FD-1023 reports which were issued in the CHS Discovery as l\1N\VR_0059582, 

l\1N\VR _ 0059583, .rv1N\VR _ 0059585, l\1N\VR _ 0059586, .rv1N\VR _ 0059590, .rv1N\VR _ 0059591, 

l\1N\VR_0059594,.rv1N\VR_0059595,.rv1N\VR_0059596,.rv1N\VR_0059598,.rv1N\VR_0059599, 

and .rv1N\VR 0059600. 

31. On December 23, 2016, in the Comments section of Burns Chronicles No 49, an 

individual posted the following question: "Gary, Are you going to publish these government 

forms?" Later that same day HUNT replied: 

Absolutely not. First, there were conditions set by my source. Second, each document is 

clearly marked, "Dissemination Limited by Court Order". Though I don't see that I am 

bound by the Court Order, I have agreed not to disseminate them. Now, as to whether the 

source disseminated them, I think not. That is because of out (sic) agreement that I would 

only excerpt from hem (sic), and that is all that I intend to do. There are many that 

question whether I am falsely representing what they say. That is their prerogative. All of 

us read things. \\Then we are finished reading, we decide whether we believe them, or not. 

I stand behind what I have written, and I am willing to discuss them with the subjects, on 

Internet radio, if they prefer. However, exception of l\1cConnell, none of even declared 

their innocence, at least t te (sic) best of my knowledge. I will state that all that I know 

from my investigation is not necessarily included in my articles. Perhaps, if they know 

that, it would explain their silence. I find myself, once again having to deal with my 

accusers, however, I don't run from it-I take it head on. 

32. On December 28, 2016, an article by HUNT titled "Bums Chronicles No 51" was 

posted on the Outpost of Freedom blog at http://outpost-of-freedom.com. This article alleges 

\VK was an FBI informant and publishes information from several CHS Discovery reports. I 

have reviewed the CHS Discovery and observed the information published by Hunt to exactly 

Affidavit of FBI SA Walker Page 9 

Case 3:16-cr-00051-BR Document 1681 Filed 01/06/17 Page 9 of 11
match FD-1023 reports which were issued in the CHS Discovery as MNWR _ 0059646, 

MNWR_0059650,MNWR_0059651,MNWR_0059652,MNWR_0059648,MNWR_0059653, 

MNWR_0059654, and MNWR_0059655. 

33. Following the arrest of all of the above named defendants in this investigation, I 

was tasked with assisting the United States Attorney's Office with discovery matters and with 

trial preparation. In that capacity, I became aware of the defense attorneys and their staff for the 

above named defendants. Further, I attended the above mentioned September/October 2016 trial 

and routinely worked with the defense attorneys and their staff. I have spoken with Assistant 

United States Attorney (AUSA) Geoffrey Barrow who was primarily responsible for discovery 

production and was one of the prosecutors for the September/October trial. To my knowledge, 

and according to AUSA Barrow, Gary HUNT was never identified as a member of the staff of 

any of the defense counsel for the above named defendants nor was he a person who had any 

legitimate reason to possess any discovery from this investigation. 

34. On January 5, 2017, Special Agent Matthew Catalano telephonically contacted 

Gary HUNT and requested a meeting. Before agreeing to meet Agent Catalano, HUNT 

confirmed there was no arrest warrant issued for him. Agent Catalano and HUNT met at a 

restaurant near HUNT's residence. During the meeting HUNT acknowledged he knew of the 

court order limiting dissemination of the discovery material but stated he was not bound by the 

court order. HUNT was provided a copy of a letter from AUSA Pamala Holsinger which 

demanded HUNT to cease and desist public dissemination of protected material within 24 hours. 

HUNT was also provided a copy of the final Protective Order, court record 342. HUNT said he 

anticipated a cease and desist order from the government. HUNT indicated he did not intend to 

comply with the terms of the letter. HUNT said if it could be proven that his actions were 

statutorily criminal he would stop doing what he is doing. HUNT informed Special Agent 

Catalano that he had two more articles outing CHSs in their final review stage before he uploads 

them. HUNT stated it was necessary to out the CHSs so they could serve as defense witnesses in 

the next trial. This meeting concluded at approximately 12:20 PM. 

Affidavit of FBI SA Walker Page 10 

Case 3:16-cr-00051-BR Document 1681 Filed 01/06/17 Page 10 of 11
35. As of3:00 PM today, January 6, 2017, Gary HUNT has not removed the 

protected content from the Outpost of Freedom blog at http://outpost-of-freedom.com nor has he 

contacted Special Agent Catalano to arrange for the return of the discovery materials. 

36. Based on the foregoing, I believe that Gary HUNT has disseminated and 

continues to disseminate the discovery materials in violation of the final Protective Order, court 

record 342. 

Ronnie Walk~-=-== 

Special Agent 

Federal Bureau of Investigation 

SUBSCRIBED AND SWORN to before me this 6~ y of January 2017. 

OFFICIAL STAMP 

KENNETH M SCANLON 

NOTARY PUBLIC-OREGON 

COMMISSION NO. 921481 

MY COMMISSION EXPIRES OCTOBER 24, 2017 

Affidavit of FBI SA Walker 

NOTARY PUBLIC FOR OREGON 

Page 11 

Case 3:16-cr-00051-BR Document 1681 Filed 01/06/17 Page 11 of 11