PAGE 1. JOINT STATUS REPORT ON DISCOVERY MANAGEMENT

Amy Baggio, OSB #011920

amy@baggiolaw.com

Baggio Law

621 SW Morrison, Suite 1025

Portland, OR 97205

Tel: (503) 222-9830

Fax: (503) 274-8575

Attorney for Defendant O’Shaughnessy

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF OREGON

PORTLAND DIVISION

UNITED STATES OF AMERICA,

Plaintiff,

v.

AMMON BUNDY, JON RITZHEIMER,

JOSEPH O’SHAUGHNESSY, RYAN 

PAYNE, RYAN BUNDY, BRIAN 

CAVALIER, SHAWNA COX, PETER 

SANTILLI, JASON PATRICK, DUANE 

LEO EHMER, DYLAN ANDERSON,

SEAN ANDERSON, DAVID LEE FRY,

JEFF WAYNE BANTA, SANDRA LYNN 

PFEIFER ANDERSON, KENNETH 

MEDENBACH, BLAINE COOPER, 

WESLEY KJAR, COREY LEQUIEU, 

NEIL WAMPLER, JASON CHARLES 

BLOMGREN, DARRYL WILLIAM 

THORN, GEOFFREY STANKE, TRAVIS 

COX, and ERIC LEE FLORES

Defendants.

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

JOINT STATUS REPORT ON 

DISCOVERY MANAGEMENT

Case 3:16-cr-00051-BR Document 337 Filed 03/23/16 Page 1 of 3
PAGE 2. JOINT STATUS REPORT ON DISCOVERY MANAGEMENT

The defendants, through Amy Baggio, and the government, through AUSA Craig 

Gabriel, submit the following Joint Status Report On Discovery Management, in accordance 

with the Court’s Order of March 9, 2016 (Docket No. 285, Sealed). 

CERTIFICATION OF CONFERRAL: Undersigned counsel certifies that Assistant 

United States Attorney Craig Gabriel was provided a copy of, and consulted regarding the 

content of, this Joint Status Report On Discovery Management. The government positions as to 

the processes requested in this Status Report are set forth below. 

The parties, through Amy Baggio on behalf of the defendants1, and the government through 

AUSA Craig Gabriel, submit the following joint status report regarding the process for the 

government to make the discovery available to all defendants, in accordance with the Court’s 

Case Management Order of March 9, 2016 (Docket No. 285, Sealed). The government states that 

discovery will be produced in multiple formats, and derived from different sources, including but 

not limited to text documents, photographs, audio recordings, video recordings, images from 

electronic devices, and captures from traditional and social media. The government anticipates 

providing multiple terabytes of digital data, perhaps up to six or ten. To ensure timely, complete, 

and efficient production of discovery, the parties propose the following for the government’s 

provision of discovery in this matter: 

Joint Proposal Regarding Discovery Management 

A. The government will continue to send an email to each lead defense attorney on the case 

and the CJA Panel Office when each volume of discovery is ready for release; 

 1 Because counsel for Joseph O’Shaughnessy has been unable to have any communication with 

him since March 3, 2016, when he was arrested in Phoenix, Arizona, on the Nevada indictment, 

Ms. Baggio can make no representations on Mr. O’Shaughnessy’s behalf. Undersigned counsel 

is filing this report in her role as coordinating panel attorney.

Case 3:16-cr-00051-BR Document 337 Filed 03/23/16 Page 2 of 3
PAGE 3. JOINT STATUS REPORT ON DISCOVERY MANAGEMENT

B. The government will confer with the CJA Panel Office in advance of producing 

discovery, and provide notice to the Panel Office, when possible, as to the nature and size 

of the expected production; 

C. In terms of actual production of subsequent volumes of discovery, the government will 

send one copy to the CJA Panel Office, after conferring with the CJA Panel Office, for 

hosting and organizing by a third-party vendor.

2

Additional Defense Request Regarding Discovery

As to Item C, above, the defense further requests that the government provide one copy 

of each distribution of discovery to each individual defense attorney who requests it, on a 

defense-provided external hard drive. 

The government objects to this request. 

Respectfully submitted on March 23, 2016.

/s/ Amy Baggio

Amy Baggio, OSB #011920

503-222-9830

Attorney for Defendant O’Shaughnessy

 2 The CJA Panel Office is in the process of retaining a third party vendor. Necessary paperwork 

related to those efforts will be submitted to the Court in the normal course for budget approval. 

Case 3:16-cr-00051-BR Document 337 Filed 03/23/16 Page 3 of 3