Jeanette Finicum 

P.O. Box 918 

Colorado City, AZ 86021 

Prose 

IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF OREGON 

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

Plaintiff, 

v. 

JASON PATRICK, et al., 

Defendants. 

REPLY TO GOVERNMENT'S 

RESPONSE IN OPPOSITION TO 

JEANETTE FINICUM'S 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 to the Original Petition was filed on December 

18, 2017. 

5. There was also a Declaration of Travis Welter in support of the Response filed on 

December 18, 2017. 

6. I filed an Amended Petition for Ancillary Proceeding to Recover Property on January 19, 

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REPLY TO GOVERNMENT'S RESPONSE IN OPPOSTITION TO JEANETTE FINICUM'S 

AMENDED PETITION FOR ANCILLARY PROCEEDING TO RECOVER PROPERTY 
2018, to request the correct rifle belonging to my husband. 

7. I received the Government's Response in Opposition to the Amended Petition 

("Response") and the Declaration of Travis Welter in support of the Response to the Amended 

Petition ("Declaration") on March 16, 2018. 

I reply to the Response and Declaration as follows: 

My Property Interest In Aldo Uberti .45 caliber rifle, model 1982, serial number T1490 

8. In the Declaration paragraph 4, Mr. Welter stated that the ATF could not trace the firearm 

because there was no importer stamp on the rifle. 

9. An importer stamp is not required on firearms and decreases the value of the firearm. My 

husband valued his firearms and wanted to keep them in the best condition he could. 

10. In the Response on page 3, the government claimed that the evidence I provided in the 

Original Petition was not sufficient to establish my claim to the rifle and suggested that a receipt 

of purchase would be sufficient. 

11. I have searched in an attempt to find a receipt of purchase for the rifle, however, my 

husband purchased the firearm over two decades ago and may or may not have kept the receipt. 

Although I have been unable to locate the receipt for purchase of the rifle at this point, I have 

attached with this reply a photograph taken in 1998 of my husband holding the rifle in question. 

12. In the Declaration paragraph 5, Mr. Welter concluded that my husband may have used the 

rifle at some point during the MNWR occupation but that he did not have any additional 

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REPLY TO GOVERNMENT'S RESPONSE IN OPPOSTITION TO JEANETTE FINICUM'S 

AMENDED PETITION FOR ANCILLARY PROCEEDING TO RECOVER PROPERTY 
information to indicate that my husband had any legal right, title, or ownership interest in this 

firearm. He also stated that it was not uncommon for the occupiers to share firearms, particularly 

during guard duty. 

13. Mr. Welter's Declaration indicates that the firearm depicted in the pictures and videos he 

has reviewed fits the description of the rifle. The issue Mr. Welter raises is that there was no 

evidence presented outside of the pictures taken during the occupation that would prove my 

husband had any legal right, title, or ownership interest in the firearm. The attached picture was 

taken nearly two decades before the occupation and shows my husband's ownership by a 

preponderance of the evidence. 

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

14. The government and Mr. Welter stated in the Response and Declaration that these 

pleadings were meant to supplement the initial response and declaration to my Original Petition. 

In the Response page 2 foot note 1, the government states that the response to my claim for the 

revolver remains the same. In Mr. Welter's first declaration paragraphs 14 and 15, he stated that 

a Firearms Trace Summary was requested and that the A TF found my husband had purchased the 

revolver in question. 

15. The government claimed that this revolver was part of a civil forfeiture case to be 

adjudicated at a later time. If that is the case, I reassert my property interest in the revolver and 

acknowledge that the government has already conceded that the ATF trace discovered my husband 

had legal right, title, and ownership of the revolver. 

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REPLY TO GOVERNMENT'S RESPONSE IN OPPOSTITION TO JEANETTE FINICUM'S 

AMENDED PETITION FOR ANCILLARY PROCEEDING TO RECOVER PROPERTY 
I request a hearing on this matter, unless the Court deems it unnecessary in granting my 

request for the rifle to be returned to me. 

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

best of my knowledge. Executed on this 31st day of March, 2018. 

Isl Jeanette Finicum 

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REPLY TO GOVERNMENT'S RESPONSE IN OPPOSTITION TO JEANETTE FINICUM'S 

AMENDED PETITION FOR ANCILLARY PROCEEDING TO RECOVER PROPERTY 
CERTIFICATE OF SERVICE 

I hereby certify that on March 31, 2018, I made arrangements for the document titled 

Reply to Government's Response in Opposition to Jeanette Finicum's Amended Petition for 

Ancillary Proceeding to Recover Property along with the 1998 photograph of my husband 

holding the firearm in question 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 Reply to 

Government's Response in Opposition to Jeanette Finicum's Amended Petition for Ancillary 

Proceeding to Recover Property with the 1998 photograph of my husband holding the firearm in 

question, 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 Reply to Government's Response 

in Opposition to Jeanette Finicum's Amended Petition for Ancillary Proceeding to Recover 

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REPLY TO GOVERNMENT'S RESPONSE IN OPPOSTITION TO JEANETTE FINICUM'S 

AMENDED PETITION FOR ANCILLARY PROCEEDING TO RECOVER PROPERTY 
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 

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REPLY TO GOVERNMENT'S RESPONSE IN OPPOSTITION TO JEANETTE FINICUM'S 

AMENDED PETITION FOR ANCILLARY PROCEEDING TO RECOVER PROPERTY