Jeanette Finicum 

P.O. Box 918 

Colorado City, AZ 86021 

Prose 

IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF OREGON 

UNITED ST ATES OF AMERICA, Case No. 3:16-cr-00051-BR 

Plaintiff, 

V. 

JASON PATRICK, et al., 

Defendants. 

AMENDED PETITION FOR 

ANCILLARY PROCEEDING TO 

RECOVER PROPERTY 

1. My name is Jeanette Finicum, and I am the widow of Robert LaVoy Finicum. 

2. As LaVoy's widow, and the representative ofLaVoy's Estate, I was served with a copy of 

a Notice of Forfeiture("Notice"), filed as Document 1903 in the above-referenced action. 

3. I filed a Petition for Ancillary Proceeding to Recover Property ("Original Petition") on 

December 5, 2017. 

4. The Government's Response in Opposition ("Response") to the Original Petition was filed 

on December 18, 2017. 

5. There was also a Declaration of Travis Welter ("Declaration") in support of the Response 

filed on December 18, 201 7. 

6. Based on the information related in the Response and Declaration, I amend my Original 

Petition as follows: 

1 

AMENDED PETITION FOR ANCILLARY PROCEEDING TO RECOVER PROPERTY 

i 

i 

! 

I 

I 

I 

I 

I i 

~ 

t 

~ .

f

~ 

f 

r 

t 

I 

Case 3:16-cr-00051-BR Document 2444 Filed 01/29/18 Page 1 of 4
My Property Interest In Aldo Uberti .45 caliber rifle, model 1982, serial number Tl490 

7. In that Notice, filed as Document 1903 in the above-referenced action, and based on the 

Response and Declaration filed in this case, and based on my personal knowledge and information 

provided by others who are knowledgeable about the materials listed in that Notice, I hereby assert 

an interest in the property identified as "Aldo Uberti .45 caliber rifle, model 1982, serial number 

T1490." 

8. Based on the Response and Declaration filed in this case, my personal knowledge, and 

information shared with me from other knowledgeable people, I declare that this rifle belonged to 

my husband, LaVoy. I attached to the Original Petition a few photos that I recognize and 

understand to have been taken of La Voy while he was holding or carrying the rifle (in its scabbard, 

as he usually carried it) in the January 2016 time period, while LaVoy was at the Malheur Refuge 

located in Harney County, Oregon. These photos and others showing LaVoy with the rifle and 

scabbard are also available online. 

9. As the representative of Lavoy's Estate, I request that this rifle, with its scabbard and any 

other accessories be returned to me. 

10. I also request a hearing, unless the Court deems it unnecessary in granting my request for 

the rifle to be returned to me. 

My Property Interest In An Additional Firearm - Rossi .38 Revolver 

11. As an additional matter, I understand that the government may have in its possession 

another firearm that belonged to my husband, La Voy: a Rossi .38 Revolver. 

12. I have been informed by persons knowledgeable that, at the trial held in the above2 

AMENDED PETITION FOR ANCILLARY PROCEEDING TO RECOVER PROPERTY 

Case 3:16-cr-00051-BR Document 2444 Filed 01/29/18 Page 2 of 4
referenced matter in the September-October 2016 time period, the government marked this Rossi 

.38 Revolver that belonged to my husband as Government Exhibit 426. I understand that it was 

also identified by the government's identification number 1B913. Finally, I understand that the 

defendants standing trial at that time marked a potential exhibit as Defendants' Exhibit 1375, 

which I understand was an ATF report confirming that my husband, LaVoy, was the owner of this 

Rossi .38 Revolver. 

13. Accordingly, as the representative of my husband's estate, I assert a property interest in 

that firearm, and I request that the government return it to me as well. If the Court deems it 

necessary, I also request a hearing regarding that matter, though I will admit that, unlike the rifle 

identified above, it does not appear that the Rossi .38 Revolver was listed on the Notice filed as 

Document 1903 in the above-referenced matter, and that I am not currently aware of any Notice 

of Forfeiture filed by the government regarding that firearm. 

I declare under penalty of perjury that the foregoing is true and correct according to the 

best of my knowledge. Executed on this 23rd day of January, 2018. 

Isl Jeanette Finicum 

3 

AMENDED PETITION FOR ANCILLARY PROCEEDING TO RECOVER PROPERTY 

I 

I 

i 

I 

I 

I 

~ 

I 

f 

~ 

E 

l 

Case 3:16-cr-00051-BR Document 2444 Filed 01/29/18 Page 3 of 4
CERTIFICATE OF SERVICE 

I hereby certify that on January 23, 2018, I made arrangements for the document titled 

Amended Petition for Ancillary Proceeding to Recover Property to be filed and served in the 

above-referenced matter by placing a copy in a first-class postage paid envelope, to be delivered 

via U.S. mail, to the addressee set forth below: 

Assistant United States Attorney Katherine C. de Villiers 

1000 SW Third Avenue, Suite 600 

Portland, OR 97204 

And, to be delivered to the Clerk of the Court for filing, the original Amended Petition 

for Ancillary Proceeding to Recover Property, mailed to the following address: 

Clerk of Court 

U.S. District Court, District of Oregon 

1000 SW Third Avenue, Suite 740 

Portland, OR 97204-2902 

Finally, I arranged to have one additional copy of the Amended Petition for Ancillary 

Proceeding to Recover Property included with the original, and I request that the clerk of the 

court file-stamp that copy and return it to me, using the enclosed pre-stamped and self-addressed 

envelope. 

Isl Jeanette Finicum 

Jeanette Finicum 

P.O. Box 918 

Colorado City, AZ 86021 

4 

AMENDED PETITION FOR ANCILLARY PROCEEDING TO RECOVER PROPERTY 

Case 3:16-cr-00051-BR Document 2444 Filed 01/29/18 Page 4 of 4